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Elias Koumniotes

IRS Issues 2019 Updates for Ruling Requests, Technical Advice, and No-Rule Procedures

IRS Issues 2019 Updates for Ruling Requests, Technical Advice, and No-Rule Procedures The IRS has issued its annual revisions to the general procedures for ruling requests, technical memoranda, determination letters, and user fees, as well as areas on which the Associate Chief Counsel offices will not rule. The revised procedures are generally effective January 2, […]

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Wayne Naegele

Wayfair decision and impacts on your business

Wayfair decision and impacts on your business On June 21, 2018, the Supreme Court of the United States handed down a historic decision in the sales and use tax nexus case South Dakota v. Wayfair, Inc. The 5-4 ruling overturns physical presence standards upheld in previous cases, such as Quill Corp. v. North Dakota (1992) […]

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Donald Sager

Proposed Regs Address Foreign Tax Credit Changes

Proposed Regs Address Foreign Tax Credit Changes Highly anticipated foreign tax credit regulations have been issued that provide guidance on the significant changes made to the foreign tax credit rules by the Tax Cuts and Jobs Act ( P.L. 115-97). The proposed regulations address: allocation and apportionment of the deductions under Code Secs. 861 through […]

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Steve Grgas

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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Steve Grgas

Proposed Regs Provided for Code Sec. 163(j) Limit

Proposed Regs Provided for Code Sec. 163(j) Limit The IRS has proposed regulations on the limitation on the business interest expense deduction under Code Sec. 163(j), as amended by the Tax Cuts and Jobs Act (TCJA) ( P.L. 115-97). The IRS also has issued a safe harbor that allows taxpayers to treat certain infrastructure trades […]

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