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Final Regs Revert Back to Prior Partnership Disguised Sale Rules

dsager

Final Regs Revert Back to Prior Partnership Disguised Sale Rules

Final Regs Revert Back to Prior Partnership Disguised Sale Rules New final regulations that address the allocation of partnership liabilities for disguised sale purposes revert back to prior regulations. Under the final regulations: a partner’s share of a recourse liability of the partnership equals the partner’s share of the liability under the rules of Code […]

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dsager

Proposed Regs Address Tax Implications of LIBOR Elimination

Proposed Regs Address Tax Implications of LIBOR Elimination Proposed regulations provide guidance on the potential tax consequences of replacing the London interbank offered rates (LIBORs) with a new reference rate in contracts and agreements. On July 27, 2017, the U.K. Financial Conduct Authority announced that all currency and term variants of the LIBORs may be […]

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sgrgas

Final Regulations on 100 Percent Bonus Depreciation Issued, Along With New Proposals

Final Regulations on 100 Percent Bonus Depreciation Issued, Along With New Proposals Final regulations dealing with the 100 percent bonus depreciation allowance for qualified property acquired and placed in service after September 27, 2017, allow property which is constructed under a pre-September 28, 2017 binding contract to qualify for the 100 percent rate. The final […]

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srusso

Final Regulations on 100 Percent Bonus Depreciation Issued, Along With New Proposals

Final Regulations on 100 Percent Bonus Depreciation Issued, Along With New Proposals Final regulations dealing with the 100 percent bonus depreciation allowance for qualified property acquired and placed in service after September 27, 2017, allow property which is constructed under a pre-September 28, 2017 binding contract to qualify for the 100 percent rate. The final […]

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tzanata

Proposed Regulations Provide Guidance on Section 382(h) Built-in Gain and Loss Computation

Proposed Regulations Provide Guidance on Section 382(h) Built-in Gain and Loss Computation Proposed regulations would provide guidance on the inclusion of income and deduction items in the calculation of built-in gains and losses under Code Sec. 382(h). The proposed regulations would: simplify the application of Code Sec. 382; provide more certainty to taxpayers in determining […]

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ttasch

Proposed Regulations Provide Guidance on Section 382(h) Built-in Gain and Loss Computation

Proposed Regulations Provide Guidance on Section 382(h) Built-in Gain and Loss Computation Proposed regulations would provide guidance on the inclusion of income and deduction items in the calculation of built-in gains and losses under Code Sec. 382(h). The proposed regulations would: simplify the application of Code Sec. 382; provide more certainty to taxpayers in determining […]

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tzanata

Final Regulations Amend Hardship Distribution Rules from Section 401(k) Plans

Final Regulations Amend Hardship Distribution Rules from Section 401(k) Plans The IRS has issued final regulations that amend the rules relating to hardship distributions from Code Sec. 401(k) plans. The final regulations are substantially similar to the proposed regulations. Further, plans that complied with the proposed regulations satisfy the final regulations as well. The regulations […]

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tzanata

Proposed Regulations Released on Applicable Financial Statement for All-Events Test

Proposed Regulations Released on Applicable Financial Statement for All-Events Test For a taxpayer using an accrual method of accounting, the all events test is not met for item of gross income any later than when is included in revenue on an applicable financial statement (AFS) or other financial statement specified by the Treasury Secretary. How […]

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wnaegele

Advance Payment Proposed Regulations Released

Advance Payment Proposed Regulations Released Proposed regulations provide rules for accrual method taxpayers who receive advance payments. The proposed regulations include provisions affecting both taxpayers both with and without applicable financial statements (AFS), and describe and clarify the statutory requirements of Code Sec. 451(c). Similar to Rev. Proc. 2004-34The proposed regulations include many provisions similar […]

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tzanata

Automatic Accounting Change Procedures for All Events Test and Advance Payment Deferral

Automatic Accounting Change Procedures for All Events Test and Advance Payment Deferral Taxpayers may use the automatic consent procedures to change accounting methods to comply with the recent proposed regulations described above. Rev. Proc. 2018-31, I.R.B. 2018-22, 637, is modified. The proposed regulations provide rules for: inclusion in gross income under the all events test […]

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