(212) 736-0055 info@pntax.com

Schedule Your Small Business Success Consultation

CFC Partners Required to Increase E&P for Subpart F Inclusions

srusso

CFC Partners Required to Increase E&P for Subpart F Inclusions

CFC Partners Required to Increase E&P for Subpart F Inclusions The upper-tier controlled foreign corporation (CFC) partners of a domestic partnership were required to include in gross income their distributive share of income inclusions under subpart F from lower-tier CFCs, and increase earnings and profits (E&P) by the same amount. Regulations under Code Sec. 964provided preliminary […]

Read more
tzanata

Wolters Kluwer Interview: A Two-Part Q&A Series on the Section 199A Deduction (Part 1)

Wolters Kluwer Interview: A Two-Part Q&A Series on the Section 199A Deduction (Part 1) Republicans’ 2017 overhaul of the tax code created a new 20-percent deduction of qualified business income (QBI), subject to certain limitations, for pass-through entities (sole proprietorships, partnerships, limited liability companies, or S corporations). The controversial QBI deduction—also called the “pass-through” deduction—has remained an […]

Read more
tzanata

Wolters Kluwer Interview: A Two-Part Q&A Series on the Section 199A Deduction (Part 2)

Wolters Kluwer Interview: A Two-Part Q&A Series on the Section 199A Deduction (Part 2) Republicans’ 2017 overhaul of the tax code created a new 20-percent deduction of qualified business income (QBI), subject to certain limitations, for pass-through entities (sole proprietorships, partnerships, limited liability companies, or S corporations). The controversial QBI deduction—also called the “pass-through” deduction—has remained an […]

Read more
tzanata

Bipartisan House Bill Aims to Fix “Retail Glitch”

Bipartisan House Bill Aims to Fix “Retail Glitch” A bipartisan House bill has been introduced that would fix a GOP tax law drafting error known as the “retail glitch.” The House bill, having over a dozen co-sponsors, is a companion measure to a bipartisan Senate bill introduced in March. Immediate Expensing The Restoring Investment in Improvements Act […]

Read more
aaguanno

House Approves Bipartisan IRS Reform Bill

House Approves Bipartisan IRS Reform Bill The House on April 9 approved by voice vote a bipartisan, bicameral IRS reform bill. The IRS bill, which now heads to the Senate, would redesign the IRS for the first time in over 20 years. IRS Reform The Taxpayer First Act of 2019 (HR 1957), as amended, cleared […]

Read more
wnaegele

Proposed Reliance Regs Address Qualified Opportunity Funds, Zones and Businesses

Proposed Reliance Regs Address Qualified Opportunity Funds, Zones and Businesses Proposed regulations address gains that may be deferred when taxpayers invest in a qualified opportunity fund (QOF). Taxpayers may generally rely on these new proposed regulations. The IRS has also requested comments. The proposed regulations also withdraw and replace placeholder provisions in an earlier set […]

Read more
tzanata

Safe Harbor Provided for Basis of Professional Sports Contracts for Players Traded Between Teams

Safe Harbor Provided for Basis of Professional Sports Contracts for Players Traded Between Teams The IRS has provided a safe harbor for professional sports teams to avoid the recognition of gain or loss when trading players and/or draft picks. Under the safe harbor provision, the traded player’s contract or the traded draft pick would have […]

Read more
apresti

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 […]

Read more
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 […]

Read more
dsager

Correction to Penalty Relief for Missing Negative Tax Basis Capital Account Info

Correction to Penalty Relief for Missing Negative Tax Basis Capital Account Info The IRS has corrected Notice 2019-20, which provided a waiver of penalties under Code Secs. 6722(failure to furnish correct payee statements) and 6698 (failure to file partnership return) for certain partnerships that file and furnish Schedules K-1 to Form 1065 without reporting negative tax basis capital account […]

Read more