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

tzanata

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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bwhelan

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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sgrgas

Wyden Urges Treasury, IRS to “Do More” to Waive Underpayment Penalties

Wyden Urges Treasury, IRS to “Do More” to Waive Underpayment Penalties The Senate’s top Democratic tax writer is calling on the IRS and Treasury to further waive underpayment penalties for the 2018 tax year. Nearly 30 million taxpayers are expected to have underpaid taxes last year, according to the Government Accountability Office (GAO). Underpayment Penalty […]

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bwhelan

Senators Introduce Bipartisan Craft Beverage Modernization and Tax Reform Bill

Senators Introduce Bipartisan Craft Beverage Modernization and Tax Reform Bill Senators have introduced a bipartisan bill specifically tailored to reduce excise taxes and regulations for the U.S. craft beverage industry. The bill aims to promote job creation and permanently reduce certain taxes and compliance burdens. Craft Beverage Tax Reform The Craft Beverage Modernization and Tax […]

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bwhelan

Opportunity Zone’s Tax Writers, Stakeholders Criticize IRS’s 50-Percent Locational Rule

Opportunity Zone’s Tax Writers, Stakeholders Criticize IRS’s 50-Percent Locational Rule The IRS’s proposed 50-percent gross income locational rule on the active conduct of Opportunity Zone businesses is garnering criticism from stakeholders and lawmakers alike. The IRS released proposed regulations, NPRM REG-115420-18, for tax reform’s Opportunity Zone program last October. 50-Percent Locational Rule Many stakeholders have urged […]

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aaguanno

IRS Postpones Canceling Tax Transcript Faxing Service After Grassley, Wyden Urge Delay

IRS Postpones Canceling Tax Transcript Faxing Service After Grassley, Wyden Urge Delay The IRS has said that it is postponing its plan to discontinue faxing taxpayer transcripts. The IRS statement came on the heels of a letter sent earlier this week from bipartisan leaders of the Senate Finance Committee urging such a delay. IRS Cybersecurity […]

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ttasch

Guidance on 2019 Withholding Rules

Guidance on 2019 Withholding Rules The IRS has provided interim guidance for the 2019 calendar year on income tax withholding from wages and withholding from retirement and annuity distributions. In general, certain 2018 withholding rules provided in Notice 2018-14, I.R.B. 2018-7, 353, will remain in effect for the 2019 calendar year, with one exception. The […]

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ekoumniotes

IRS Extends Passthrough Deduction to Real Estate Rental Activities, Provides Other Guidance

IRS Extends Passthrough Deduction to Real Estate Rental Activities, Provides Other Guidance New IRS guidance fills in several more pieces of the Code Sec. 199A passthrough deduction puzzle. Taxpayers can generally rely on all of these new final and proposed rules. Final Regulations The final regulations in T.D. 98xx_1 largely adopt the proposed regulations in NPRM REG-107892-18 (August 16, 2018), but […]

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ekoumniotes

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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srusso

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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