TAM 201929019: Deemed Partnership Distribution Treated as Exchange

In TAM 201929019, the deemed distribution of a partnership interest in an assets-over merger of two partnerships was treated as a Code Sec. 761(e) "exchange," which required a mandatory Code Sec. 743(b) downward inside-basis adjustment when the resulting partnership had a substantial built-in loss. The issues presented and rulings made were as follows: Issues: 1. Is … Continue reading TAM 201929019: Deemed Partnership Distribution Treated as Exchange

Draft 2019 Form 1040 + Schedules Released

The IRS has released its draft 2019 Form 1040 along with associated schedules. See draft 1040 and schedules by clicking links below: Form 1040 (Schedule 8812)Additional Child Tax CreditForm 1040 (Schedule R)Credit for the Elderly or the DisabledForm 1040-SRU.S. Tax Return for SeniorsForm 1040-NR-EZU.S. Income Tax Return for Certain Nonresident Aliens With No DependentsForm 1040 … Continue reading Draft 2019 Form 1040 + Schedules Released

IRS Tax Tip 2019-94: Here’s how individual taxpayers can view their tax account info

According to the IRS, taxpayers with questions about their federal tax accounts can hop over to IRS.gov for answers. Individual taxpayers can login to the View Your Account Information page to view specific details about their federal tax account information. Taxpayers can view: Their payoff amount, which is updated for the current day.The balance for each tax year for … Continue reading IRS Tax Tip 2019-94: Here’s how individual taxpayers can view their tax account info

Hales & Tingey, Sec. 1341: What is the claim-of-right doctrine?

Adam Hales, CPA, and Dennis Tingey, CPA, have published their article, Sec. 1341: What is the claim-of-right doctrine? in the AICPA Tax Adviser. The introduction is as follows: The law known as the Tax Cuts and Jobs Act (TCJA), P.L. 115-97, enacted Dec. 22, 2017, made numerous changes to the U.S. tax rules affecting businesses and … Continue reading Hales & Tingey, Sec. 1341: What is the claim-of-right doctrine?

Proposed Regs: Passive foreign investment companies (PFICs) and PFIC insurance exception

The Treasury Department and IRS has released proposed regulations (REG-105474-18) regarding passive foreign investment companies (PFICs) and specifically concerning legislative changes made by the Tax Cuts and Jobs Act of 2017 with regard to the “PFIC insurance exception.” The Regs summary is as follows: This document contains proposed regulations under sections 1291, 1297, and 1298 … Continue reading Proposed Regs: Passive foreign investment companies (PFICs) and PFIC insurance exception

Joint Committee on Taxation Description of President Trump’s FY 2020 Budget Recommendations, including Proposal to Make Permanent Individual Tax Provisions, Including Estate & Gift Tax Provisions

The Joint Committee on Taxation has made available it's description of revenue provisions in President Trump's FY 2020 Budget Proposal. These include the proposal to make permanent the individual tax provisions that sunset for tax years beginning on or after January 1, 2026, including the estate and gift tax provisions, among others. To see the … Continue reading Joint Committee on Taxation Description of President Trump’s FY 2020 Budget Recommendations, including Proposal to Make Permanent Individual Tax Provisions, Including Estate & Gift Tax Provisions