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Elias Koumniotes

Interim Guidance for Excise Tax on Excess Remuneration and Parachute Payments

Interim Guidance for Excise Tax on Excess Remuneration and Parachute Payments The IRS has issued interim guidance on the excise tax payable by exempt organizations on remuneration in excess of $1 million and any excess parachute payments made to certain highly compensated current and former employees in the tax year. The excise tax imposed by Code […]

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Salvatore Russo

Safe Harbors Provided for Business Payments Made in Exchange for SALT Credits

Safe Harbors Provided for Business Payments Made in Exchange for SALT Credits The IRS has provided safe harbors for business entities to deduct certain payments made to a charitable organization in exchange for a state or local tax (SALT) credit. A business entity may deduct the payments as an ordinary and necessary business expenses under Code […]

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Elias Koumniotes

Final Transition Tax Regulations Issued

Final Transition Tax Regulations Issued The Treasury and IRS have issued final regulations for determining the inclusion under Code Sec. 965 of a U.S. shareholder of a foreign corporation with post-1986 accumulated deferred foreign income. Code Sec. 965 imposes a “transition tax” on the inclusion. The final regulations retain the basic approach and structure of the proposed regulations, with certain changes. […]

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Elias Koumniotes

IRS Issues 2019 Updates for Ruling Requests, Technical Advice, and No-Rule Procedures

IRS Issues 2019 Updates for Ruling Requests, Technical Advice, and No-Rule Procedures The IRS has issued its annual revisions to the general procedures for ruling requests, technical memoranda, determination letters, and user fees, as well as areas on which the Associate Chief Counsel offices will not rule. The revised procedures are generally effective January 2, […]

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Wayne Naegele

Wayfair decision and impacts on your business

Wayfair decision and impacts on your business On June 21, 2018, the Supreme Court of the United States handed down a historic decision in the sales and use tax nexus case South Dakota v. Wayfair, Inc. The 5-4 ruling overturns physical presence standards upheld in previous cases, such as Quill Corp. v. North Dakota (1992) […]

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January 2019 Newsletter

Don Sager discusses, “Proposed Regs Address Foreign Tax Credit Changes”. Tom Zanata discusses, “2019 Standard Mileage Rates Released”. Lisa Varela looks at, “Guidance on Tax Benefit for Stock Options and Restricted Stock Units”.

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Donald Sager

Proposed Regs Address Foreign Tax Credit Changes

Proposed Regs Address Foreign Tax Credit Changes Highly anticipated foreign tax credit regulations have been issued that provide guidance on the significant changes made to the foreign tax credit rules by the Tax Cuts and Jobs Act ( P.L. 115-97). The proposed regulations address: allocation and apportionment of the deductions under Code Secs. 861 through […]

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Steve Grgas

Regulations to be Issued on Controlled Foreign Corporations’ Previously Taxed Earnings and Profits

Regulations to be Issued on Controlled Foreign Corporations’ Previously Taxed Earnings and Profits The IRS and the Treasury intend to provide regulations that will address issues affecting foreign corporations with previously taxed earnings and profits (PTEP). The regulations are in response to changes made by the Tax Cuts and Jobs Act (TCJA) ( P.L. 115-97), […]

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Steve Grgas

Proposed Regs Provided for Code Sec. 163(j) Limit

Proposed Regs Provided for Code Sec. 163(j) Limit The IRS has proposed regulations on the limitation on the business interest expense deduction under Code Sec. 163(j), as amended by the Tax Cuts and Jobs Act (TCJA) ( P.L. 115-97). The IRS also has issued a safe harbor that allows taxpayers to treat certain infrastructure trades […]

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Thomas Zanata

2019 Standard Mileage Rates Released

2019 Standard Mileage Rates Released The IRS released the optional standard mileage rates for 2019. Most taxpayers may use these rates to compute deductible costs of operating vehicles for: business, medical, and charitable purposes. Some members of the military may also use these rates to compute their moving expense deductions. 2019 Standard Mileage Rates The […]

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