Bloomberg Wealth: World’s Richest Face Tax Blow After 40% Wealth Surge to $8.4 Trillion (June 10, 2021)

Ben Steverman, Laura Davison, and William Horobin of Bloomberg Wealth, have recently made available their article that discusses politicians' expected endorsement of tax plans that will plug legal loopholes used by the wealthiest individuals and corporations to pay lower tax rates. Their article, "World’s Richest Face Tax Blow After 40% Wealth Surge to $8.4 Trillion," … Continue reading Bloomberg Wealth: World’s Richest Face Tax Blow After 40% Wealth Surge to $8.4 Trillion (June 10, 2021)

BDO: IRS Streamlines Automatic Consent Procedures For CFC Depreciation Method Changes, Clarifies Treatment Of Catch-Up Adjustment (June 2021)

BDO has published an article, “IRS Streamlines Automatic Consent Procedures For CFC Depreciation Method Changes, Clarifies Treatment Of Catch-Up Adjustment,” which discusses new filing procedures released by the IRS for certain foreign corporations (CFCs). The article begins as follows: On May 11, 2021, the IRS and Treasury released Rev. Proc. 2021-26, which provides streamlined filing procedures … Continue reading BDO: IRS Streamlines Automatic Consent Procedures For CFC Depreciation Method Changes, Clarifies Treatment Of Catch-Up Adjustment (June 2021)

Deloitte: Treasury ‘Green Book’ sheds additional light on Biden’s tax proposals (May 29, 2021)

Deloitte has published an article, "Treasury ‘Green Book’ sheds additional light on Biden’s tax proposals," which discusses and analyzes the Biden administration's tax proposals for the 2022 fiscal year. The article begins as follows: The White House released a fiscal year 2022 budget blueprint on May 28 that, as expected, calls for significant tax increases … Continue reading Deloitte: Treasury ‘Green Book’ sheds additional light on Biden’s tax proposals (May 29, 2021)

BDO: Georgia Enacts PTE Tax Election As Workaround To $10K Salt Cap

Tony Manners of BDO has published an article, "Georgia Enacts PTE Tax Election As Workaround To $10K Salt Cap," which discusses the logistics of Georgia's H.B. 149 and how it impacts taxation regarding pass-through entities (PTEs). The article begins as follows: Georgia enacted H.B. 149 on May 4, 2021, becoming another state to give pass-through entities (PTEs) the … Continue reading BDO: Georgia Enacts PTE Tax Election As Workaround To $10K Salt Cap

Daniel J. Hemel and Gregg D. Polsky: Equalizing the Tax Treatment of Stock Buybacks and Dividends (April 15, 2021)

Daniel J. Hemel and Gregg D. Polsky, of University of Chicago Law School and University of Georgia School of Law, have made available for download their article, "Equalizing the Tax Treatment of Stock Buybacks and Dividends." The abstract is as follows: This policy brief highlights flaws in the current federal tax treatment of stock buybacks … Continue reading Daniel J. Hemel and Gregg D. Polsky: Equalizing the Tax Treatment of Stock Buybacks and Dividends (April 15, 2021)

Corporate State Tax Updates – April 2021

Georgia Lo The following are recent significant State Corporate Tax developments for the month of April 2021 that may be of interest to estate and business planners, organized by state.  Arizona: On April 14, S.B. 1752 was signed into law, updating Arizona’s conformity to Internal Revenue Code (IRC) provisions regarding definitions of adjusted gross income … Continue reading Corporate State Tax Updates – April 2021

Rev. Proc. 2021-26: Automatic Change of Accounting Method Procedures Expanded for CFCs

The IRS has released Rev. Proc. 2021-26 which modified its automatic consent procedures in Rev. Proc. 2019-43 , I.R.B. 2019-48, 1107, to allow certain foreign corporations to change their method of accounting for deprecation to the alternative depreciation system under Code Sec. 168(g) (ADS). Additionally, terms and conditions in Rev. Proc. 2015-13 , I.R.B. 2015-5, … Continue reading Rev. Proc. 2021-26: Automatic Change of Accounting Method Procedures Expanded for CFCs

Barker v. Comm’r: Tax Court Properly Upheld Income Tax Deficiency (April 27, 2021)

In Barker v. Commissioner of Internal Revenue, No. 19-11994 (11th Cir. 2021), the Tax Court’s upholding of the IRS’s determination of an income tax deficiency (individual) was affirmed. The taxpayer started an entertainment company (partnership for tax purposes). As a passthrough entity, the company paid no income tax and its losses flow directly through to … Continue reading Barker v. Comm’r: Tax Court Properly Upheld Income Tax Deficiency (April 27, 2021)

BDO: Frequently Asked Questions Related to Employee Stock Ownership Plans (ESOPs) (April 2021)

BDO has published an article, “Frequently Asked Questions Related to Employee Stock Ownership Plans (ESOPs),” which discusses the logistics behind an ESOP, and the benefits these kinds of retirement plans can produce.  The article begins as follows: Employee ownership can be an attractive option for owners looking to sell their business while maintaining their legacy … Continue reading BDO: Frequently Asked Questions Related to Employee Stock Ownership Plans (ESOPs) (April 2021)

Daniel J. Hemel and Gregg D. Polsky: Equalizing the Tax Treatment of Stock Buybacks and Dividends (April 15, 2021)

Daniel J. Hemel and Gregg D. Polsky, of University of Chicago - Law School and University of Georgia School of Law, respectively, have made available for download their article, “Equalizing the Tax Treatment of Stock Buybacks and Dividends,” published in SSRN. The abstract is as followed: This policy brief highlights flaws in the current federal … Continue reading Daniel J. Hemel and Gregg D. Polsky: Equalizing the Tax Treatment of Stock Buybacks and Dividends (April 15, 2021)

Corporate State Tax Updates – March 2021

By Georgia Lo The following are recent significant State Corporate Tax developments for the month of March 2021 that may be of interest to estate and business planners, organized by state.  Alabama: The Alabama Court of Appeals recently upheld the state’s mandatory corporate income tax return requirement for passthrough entities with non-resident members. Under state law, … Continue reading Corporate State Tax Updates – March 2021

AICPA J. Accountancy: IRS explains which meals qualify for temporary 100% expense deduction (April 8, 2021)

Sally Schreiber has published her article, "IRS explains which meals qualify for temporary 100% expense deduction," in the AICPA Journal of Accountancy. The article, which unpacks Thursday's IRS guidance for restaurant businesses in regards to qualifying for deductions, begins as follows: The IRS released guidance on Thursday explaining when the temporary 100% deduction for restaurant … Continue reading AICPA J. Accountancy: IRS explains which meals qualify for temporary 100% expense deduction (April 8, 2021)

IRS urges participants of abusive micro-captive insurance arrangements to exit from arrangements (Apr. 9, 2021)

Internal Revenue Service officials urged participants in abusive micro-captive insurance arrangements to exit these transactions as soon as possible. The IRS has stepped up examinations of these arrangements and has recently won yet another case in U.S. Tax Court that such arrangements are not eligible for the tax benefits claimed. On March 10, 2021, the … Continue reading IRS urges participants of abusive micro-captive insurance arrangements to exit from arrangements (Apr. 9, 2021)

CCA 202114020 (Apr. 12, 2021): Bitcoin Cash Received as a Result of Bitcoin Hard Fork Included in Gross Income

In CCA 202114020, the IRS ruled on the issue of whether a taxpayer who received Bitcoin Cash as a result of the August 1, 2017, Bitcoin hard fork has gross income under section 61 of the Internal Revenue Code (Code)? The IRS reached the conclusion that, yes, a taxpayer who received Bitcoin Cash as a … Continue reading CCA 202114020 (Apr. 12, 2021): Bitcoin Cash Received as a Result of Bitcoin Hard Fork Included in Gross Income

Pallav Raghuvanshi (Greenberg Traurig LLP): Corporate Tax Hikes for Biden’s Infrastructure Plan (April 2, 2021)

Pallav Raghuvanshi, of Greenberg Traurig LLP, has have made available for download his article, "Corporate Tax Hikes for Biden’s Infrastructure Plan," published in a Greenberg Traurig Alert. The abstract is as follows: On March 11, 2021, two tax reform Bills (the Stop Tax Haven Abuse Act and the No Tax Breaks for Outsourcing Act) were introduced in both the House and the Senate … Continue reading Pallav Raghuvanshi (Greenberg Traurig LLP): Corporate Tax Hikes for Biden’s Infrastructure Plan (April 2, 2021)

IRS Practice Unit Updated: Receipt of Dividends or Interest from a Related CFC (March 29, 2021)

The IRS has updated its practice unit on receipt of dividends or interest from a related controlled foreign corporation. The overview is as follows: Note: This Unit was revised to include the extension of the IRC 954(c)(6) look through rule for CFCs with tax years beginning before January 1, 2026. This extension was part of … Continue reading IRS Practice Unit Updated: Receipt of Dividends or Interest from a Related CFC (March 29, 2021)

IRS Updates Practice Unit on Liquidating Distributions of Partners Interest in Partnership (April 2, 2021)

The IRS has updated its practice unit on liquidating distributions of a partners interest in a partnership. The overview is as follows: All partnership distributions are either current or liquidating. A liquidating distribution terminates a partner’s entire interest in the partnership. A current distribution reduces a partner’s capital accounts and basis in his interest in … Continue reading IRS Updates Practice Unit on Liquidating Distributions of Partners Interest in Partnership (April 2, 2021)

President Biden Announces The Made in America Tax Plan proposing corporate tax changes; the American Families Plan with individual tax changes coming soon (April 1, 2021)

On March 31, 2021, President Biden announced The American Jobs Plan portion of his Build Back Better program, which contains corporate tax changes in The Made in America Tax Plan. He also announced that The American Families Plan, which will propose individual tax changes will be coming soon. See the details at the following links: … Continue reading President Biden Announces The Made in America Tax Plan proposing corporate tax changes; the American Families Plan with individual tax changes coming soon (April 1, 2021)

IRS Practice Unit on Code Sec. 965 Transition Tax Updated (Mar. 23, 2021)

The IRS has updated its practice unit on the Code Sec. 965 Transition Tax. The summary is as follows: On December 22, 2017, IRC 965 was amended by “An Act to provide for reconciliation pursuant to titles II and V of the concurrent resolution on the budget for fiscal year 2018,” P.L. 115-97 (Tax Cuts … Continue reading IRS Practice Unit on Code Sec. 965 Transition Tax Updated (Mar. 23, 2021)

IRS Practice Unit on Sale of Partnership Interest Updated (March 12, 2021).

The IRS has updated its Practice Unit on the sale of a partnership interest. The overview is as follows:  When a sale of a partnership interest occurs, the entity theory is the underlying concept, not the aggregate theory. This means the ownership interest a partner has in a partnership is treated as a separate … Continue reading IRS Practice Unit on Sale of Partnership Interest Updated (March 12, 2021).