July 12, 2019
Thomas Zanata- Author's Bio
Blog Posts
0 Comments
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 […]
Read more- July 12, 2019
- Thomas Zanata
- Author's Bio
- Blog Posts
- 0 Comments
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 […]
Read more- July 12, 2019
- Thomas Zanata
- Author's Bio
- Blog Posts
- 0 Comments
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 […]
Read more- July 12, 2019
- Thomas Zanata
- Author's Bio
- Blog Posts
- 0 Comments
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 […]
Read more
- July 12, 2019
- Andrew Presti
- Author's Bio
- Blog Posts
- 0 Comments
Employers Can Offer HRAs Integrated with Individual Coverage
Employers Can Offer HRAs Integrated with Individual Coverage Final rules allow employers to use health reimbursement arrangements (HRAs) to reimburse employees for the purchase individual insurance coverage, including coverage on an Affordable Care Act Exchange. The rules also allow “excepted benefit HRAs,” which would not have to be integrated with any coverage. The rules generally apply for […]
Read more