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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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