TD 9394: Correcting amendment to final regulations: Withholding related to foreign partners for effectively connected taxable income (June 11, 2020).

Treasury and the IRS have published a correcting amendment to final regulations related to foreign partners for effectively connected taxable income on June 11, 2020. The summary for the amendment is as follows: This document contains corrections to Treasury Decision 9394, which was published in the Federal Register on Tuesday, April 29, 2008. Treasury Decision 9394 contained … Continue reading TD 9394: Correcting amendment to final regulations: Withholding related to foreign partners for effectively connected taxable income (June 11, 2020).

Proposed Regs Issued Clarifying Definition of “Qualifying Relative” and personal exemption amount

The U.S. Treasury Department and IRS have released a notice of proposed rulemaking (REG-118997-19) that is intended to clarify the definition of a “qualifying relative” for purposes of various Code provisions for tax years 2018 through 2025. With the release, part of the regulations proposed in January 2017, that address the support test for a … Continue reading Proposed Regs Issued Clarifying Definition of “Qualifying Relative” and personal exemption amount

Rev.Proc. 2020-15: Updated list of countries, deposit interest paid to nonresident aliens

Rev. Proc. 2020-15, included in Internal Revenue Bulletin 2020-23 (June 1, 2020), updates prior IRS guidance regarding the list of countries with which the United States has in force an information exchange agreement for purposes of reporting payments of deposit interest of $10 or more made by U.S. financial institutions to nonresident alien individuals. See … Continue reading Rev.Proc. 2020-15: Updated list of countries, deposit interest paid to nonresident aliens

Theron E. Johnson v. Commissioner, T.C. Memo. 2020-79 (June 8, 2020): Conservation Easement Value Calculated

In Theron E. Johnson v. Commissioner, the Tax Court ruled on the value of a conservation easement. The taxpayer believed that granting a conservation easement over his ranch would allow him in effect to create a private wildlife reserve. The court heard evidence from the taxpayer’s expert and the IRS’s expert on the value and … Continue reading Theron E. Johnson v. Commissioner, T.C. Memo. 2020-79 (June 8, 2020): Conservation Easement Value Calculated

Sage v. Commissioner, 154 T.C. 121 (June 2, 2020): No Loss on Transfer of Property to Grantor Trust

In Jason B. Sage v. Commissioner, the Tax Court held that a developer's transfer of property to a liquidating trust for the benefit of his creditors, which was a grantor trust, did not trigger a loss on the transfer of property to the trust. The opinion synopsis is as follows: P, a real estate developer, … Continue reading Sage v. Commissioner, 154 T.C. 121 (June 2, 2020): No Loss on Transfer of Property to Grantor Trust

IRS Issues Proposed Regs on Itemized Deductions for Non-Grantor Trusts

The The Internal Revenue Service today issued proposed regulations that provide guidance for estates and trusts clarifying that certain deductions of estates and non-grantor trusts are not miscellaneous itemized deductions. The Tax Cuts and Jobs Act (TCJA) prohibits individual taxpayers from claiming miscellaneous itemized deductions for any taxable year beginning after December 31, 2017, and … Continue reading IRS Issues Proposed Regs on Itemized Deductions for Non-Grantor Trusts

Rev. Rul. 2020-8: Period for Refund Claims from Foreign Tax Credit Released Due to NOL Carryback

The IRS has released Rev. Rul. 2020-8, which addresses the appropriate period for refund claims resulting from a foreign tax credit carryback that is released because of an NOL carry back from a subsequent year. To see Rev. Rul. 2020-8, click Rev. Rul. 2020-8: Period for Refund Claims from Foreign Tax Credit Released Due to … Continue reading Rev. Rul. 2020-8: Period for Refund Claims from Foreign Tax Credit Released Due to NOL Carryback

Treasury, IRS announce cross-border tax guidance related to travel disruptions arising from the COVID-19 emergency

The Treasury Department and the Internal Revenue Service have issued guidance that provides relief to individuals and businesses affected by travel disruptions arising from the COVID-19 emergency. The guidance includes the following: Revenue Procedure 2020-20 (PDF), which provides that, under certain circumstances, up to 60 consecutive calendar days of U.S. presence that are presumed to … Continue reading Treasury, IRS announce cross-border tax guidance related to travel disruptions arising from the COVID-19 emergency

AICPA Tax Insider (Apr. 16, 2020) Inherited IRA Strategies and More

IRS launches tool for nonfilers to receive stimulus payments The IRS has launched an online portal for taxpayers who are eligible to receive an economic impact payment but who are not normally required to file an income tax return because their income is too low. Inherited IRA strategies after the SECURE Act By Randy A. … Continue reading AICPA Tax Insider (Apr. 16, 2020) Inherited IRA Strategies and More

Edward A. Morse, Important Developments in Federal Income Taxation (Dec. 5, 2019)

Edward A. Morse has made available for download his paper, Important Developments in Federal Income Taxation. The Abstract is as follows: This outline covers significant developments in federal income taxation along with a few other interesting or noteworthy tax topics arising during the preceding calendar year. It offers a selective treatment focusing on items likely … Continue reading Edward A. Morse, Important Developments in Federal Income Taxation (Dec. 5, 2019)

BDO Seidman: IRS Provides Welcome Relief for Partnership Filings to Obtain CARES Act Benefits

BDO Seidman has published an article on its website about CARES Act relief for partnership filings.  Its article begins as follows: General Rules for Amending Partnership ReturnsPrior to 2018, partnerships were generally subject to unified partnership audit and litigation rules enacted by the Tax Equity and Fiscal Responsibility Act of 1982, commonly referred to as … Continue reading BDO Seidman: IRS Provides Welcome Relief for Partnership Filings to Obtain CARES Act Benefits

AICPA posts (a) 20 FAQs on tax filing relief, and (b) State Tax Filing Guidance for Coronavirus Pandemic

The AICPA has identified seven key areas in need of immediate tax relief and has posted 20 FAQs on the latest developments in taxpayer relief during the COVID-19 pandemic. The AICPA has been advocating for more comprehensive relief from Treasury and the IRS and also continues to urge the agencies to develop a contingency plan for the … Continue reading AICPA posts (a) 20 FAQs on tax filing relief, and (b) State Tax Filing Guidance for Coronavirus Pandemic

Deloitte – IRS Insights – March 2020: Tax Court Denial of Conservation easement; Enforcement Developments

Tax Court Tentatively Disallows Conservation Easement Deduction Due to Omitted Required Basis Information The Tax Court disallowed a conservation easement charitable contribution deduction because the taxpayer’s return omitted the cost or adjusted basis of the donated property from the appraisal summary and rejected the taxpayer’s argument that it strictly or substantially complied with the regulatory … Continue reading Deloitte – IRS Insights – March 2020: Tax Court Denial of Conservation easement; Enforcement Developments

IRS Releases two updated IRA publications and other online resources help taxpayers planning for retirement

The Internal Revenue Service has updated two comprehensive publications designed to help anyone making IRA contributions or receiving IRA distributions for tax year 2019 or considering making retirement donations before April 15, 2020. The 2019 editions of Publication 590-A, Contributions to Individual Retirement Arrangements (IRAs) and Publication 590-B, Distributions from Individual Retirement Arrangements (IRAs), are both now … Continue reading IRS Releases two updated IRA publications and other online resources help taxpayers planning for retirement

AICPA Tax Insider: Changes to Retirement Savings Rules (Mar. 5, 2020)

SECURE Act changes rules to encourage retirement savings: By Dave Strausfeld, J.D.The recently enacted Setting Every Community Up for Retirement Enhancement Act of 2019 modifies some rules for retirement accounts and employer plans. Supreme Court overturns consolidated group tax refund allocation rule: The U.S. Supreme Court struck down the Bob Richards rule for allocating tax refunds among members … Continue reading AICPA Tax Insider: Changes to Retirement Savings Rules (Mar. 5, 2020)

Tax Reform Implications for Fiduciaries

By Nicole Pursley The Tax Cuts and Jobs Act of 2017 (the Tax Act) made significant changes to the United States Tax Code, with implications on virtually all areas of taxation, including some that affect fiduciaries. This article provides a broad overview of some tax implications that may be of importance to trust and estate … Continue reading Tax Reform Implications for Fiduciaries

Crawford & Blattamachr: Basis and Bargain Sales: Income Tax and Other Concerns, The Tax Lawyer (2020)

Bridget J. Crawford, Pace University School of Law, and Jonathan G. Blattmachr, have made available for download their forthcoming Tax Lawyer article, Basis and Bargain Sales: Income Tax and Other Concerns. The Abstract is as follows: This article explores the income tax consequences of the sale during lifetime and at death of property for less … Continue reading Crawford & Blattamachr: Basis and Bargain Sales: Income Tax and Other Concerns, The Tax Lawyer (2020)

IRS updates guidance on business expense deductions for meals and entertainment

The Internal Revenue Service has issued proposed regulations on the business expense deduction for meals and entertainment following changes made by the Tax Cuts and Jobs Act (TCJA). The 2017 TCJA eliminated the deduction for any expenses related to activities generally considered entertainment, amusement or recreation. It also limited the deduction for expenses related to food and … Continue reading IRS updates guidance on business expense deductions for meals and entertainment

Entin: Tax Reform Presents Opportunities for Foreign Investors in U.S. Businesses Holland & Knight Alert (Feb. 20, 2020)

Seth J. Entin, of Holland & Knight, has published an article, Tax Reform Presents Opportunities for Foreign Investors in U.S. Businesses Holland & Knight Alert (Feb. 20, 2020). The abstract is as follows: The U.S. Tax Cuts and Jobs Act (the TCJA), which was enacted at the end of 2017, dramatically changed the U.S. cross-border … Continue reading Entin: Tax Reform Presents Opportunities for Foreign Investors in U.S. Businesses Holland & Knight Alert (Feb. 20, 2020)

Bloomberg Special Report: State Taxation of Passthrough Entities

Bloomberg is making available for download without charge its special report, Pass-Through Entities Face Myriad State-Level Taxes, Compliance Obligations. The summary is as follows: While pass-through entities (PTEs) are the most common form of business entities in the U.S., identifying whether a PTE is subject to tax at the state level can be surprisingly complicated.  … Continue reading Bloomberg Special Report: State Taxation of Passthrough Entities