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Thomas Zanata

Final Regs Address CPEO Requirements, Responsibilities

Final Regs Address CPEO Requirements, Responsibilities Final regulations provide requirements that a person must satisfy to become and remain a certified professional employer organization (CPEO), as well as the CPEO’s federal employment tax liabilities and other obligations. CPEOs Some employers contract with PEOs to complete and file tax returns, pay and withhold employment taxes on […]

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Thomas Zanata

Final Regulations Reduce Section 956 Income Inclusions by Domestic Corporations Owning CFC Stock

Final Regulations Reduce Section 956 Income Inclusions by Domestic Corporations Owning CFC Stock Final regulations reduce the Code Sec. 956 amount for certain domestic corporations that own stock in controlled foreign corporations (CFCs). The regulations are intended to ensure that Code Sec. 956 is applied consistently with the participation exemption system under Code Sec. 245A. Subpart F Rules Under the […]

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Thomas Zanata

Temporary Regulations Limit Application of Participation DRD To Prevent Tax Avoidance

Temporary Regulations Limit Application of Participation DRD To Prevent Tax Avoidance Newly issued temporary regulations limit the application of the Code Sec. 245A participation dividends received deduction (the participation DRD) and the Code Sec. 954(c)(6) exception in certain situations that present an opportunity for tax avoidance. The temporary regulations also provide related information reporting rules under Code Sec. 6038. Participation […]

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Thomas Zanata

Final and Proposed Regs on GILTI-Related Matters

Final and Proposed Regs on GILTI-Related Matters Final regulations address the global intangible low-taxed income (GILTI) provisions of Code Sec. 951A. The final regulations retain the basic approach and structure of the proposed regulations published on October 10, 2018. The final regulations address open questions and comments received on the proposed regulations. Final regulations on the […]

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Thomas Zanata

Proposed Rules Explain 199A Deduction for Cooperatives and Patrons

Proposed Rules Explain 199A Deduction for Cooperatives and Patrons Taxpayers may rely on two new pieces of IRS guidance for applying the Code Sec. 199A deduction to cooperatives and their patrons: Proposed regulations provide detailed rules for coop patrons and specified cooperatives to calculate the deduction. A proposed revenue procedure provides three methods for specified cooperatives to […]

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Andrew Presti

Employers Can Offer HRAs Integrated with Individual Coverage

Employers Can Offer HRAs Integrated with Individual Coverage Final rules allow employers to use health reimbursement arrangements (HRAs) to reimburse employees for the purchase individual insurance coverage, including coverage on an Affordable Care Act Exchange. The rules also allow “excepted benefit HRAs,” which would not have to be integrated with any coverage. The rules generally apply for […]

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Elias Koumniotes

Final Rules Limit Charitable Contributions Made for SALT Credits

Final Rules Limit Charitable Contributions Made for SALT Credits The IRS has issued final regulations that require taxpayers to reduce the amount any charitable contribution deduction by the amount of any state and local tax (SALT) credit they receive or expect to receive in return. The rules are aimed at preventing taxpayers from getting around […]

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Brian Whelan

Senate Tax Writers Discuss Bipartisan Retirement Savings Bills; Related House Vote Expected Soon

Senate Tax Writers Discuss Bipartisan Retirement Savings Bills; Related House Vote Expected Soon Senate tax writers on Capitol Hill continue to discuss bipartisan retirement savings bills as the House gears up for a vote on a related tax measure. The Senate Finance Committee (SFC) held a May 14 hearing during which lawmakers on both sides […]

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June 2019 Newsletter

Don Sager discusses, “Compliance Monitoring Obligations of Low-Income Housing Credit Agencies Finalized”. Steve Grgas takes a look at, “Medicaid Waiver Payments Were Earned Income Even Though IRS Excluded Them From Gross Income”. Tracy Mackin discusses, “Proposed Reliance Regs Address Qualified Opportunity Funds, Zones and Businesses”.

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Donald Sager

Compliance Monitoring Obligations of Low-Income Housing Credit Agencies Finalized

Compliance Monitoring Obligations of Low-Income Housing Credit Agencies Finalized Final regulations relating to the low-income housing tax credit revise and clarify requirements that low-income housing agencies must follow when conducting physical inspections of low-income units and reviewing low-income certifications and other documentation. The regulations finalize previously issued temporary regulations (T.D. 9753, February 25, 2016). Sample […]

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