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May 2019 - The Tax Adviser

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  2. May 2019
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GAINS & LOSSES

Opportunities beckon in new qualified opportunity zones

With their prospects for deferral or even exclusion of gains from certain investments in them, the newly created qualified opportunity zones offer an intriguing tax planning option for investors and a potential boon for distressed communities.

TAX CLINIC

CONSOLIDATED RETURNS

Considering the SRLY rules and Sec. 382 in the post-TCJA world

Managing excess loss accounts

employee benefits & pensions

Stock-based compensation: Back to basics

expenses & deductions

Sec. 199A and the aggregation of trades or businesses

Computing qualified W-2 wages for Sec. 199A purposes

REIT dividends and PTP income under Prop. Regs. Sec. 1.199A-3(d)

FOREIGN INCOME & TAXPAYERS

Proposed Sec. 956 regulations: Planning and pitfalls

GAINS & LOSSES

New limitation on excess business losses

INTEREST INCOME & EXPENSE

New CFC group election: Possible benefits

REAL ESTATE

New Sec. 163(j): Considerations for real estate and infrastructure businesses

SPECIAL INDUSTRIES

Key tax reform provisions affecting sports franchises

TAX ACCOUNTING

Updated automatic method change procedures ease transition to new revenue recognition rules

The not-so-simple aggregation rules for tax reform’s simplifying conventions

COLUMNS

NEWS NOTES

D.C. Circuit reinstates IRS PTIN fee

West Virginia cannot exempt state law enforcement pensions and tax federal ones

IRS issues safe-harbor procedure for vehicle bonus depreciation

Form 8995 will be used to calculate QBI deduction for 2019 tax returns

IRS finalizes centralized partnership audit rules

TAX PRACTICE RESPONSIBILITIES

New due-diligence standards for head-of-household filing status

Impact of Sec. 199A in computing substantial-understatement penalties

CAMPUS TO CLIENTS

Flip the tax return with a professor-prepared tax return

CASE STUDY

Structuring divisive reorganizations

TAX TRENDS

Payment of an award for lost working time is taxable compensation

IRS can again charge preparers for PTINs

employee benefits & pensions

Abstract image of pie chart, with pieces being pulled from several directions. IMAGE BY VECTORMINE/ADOBE STOCK

Profits interests: The most tax-efficient equity grant to employees

By granting them a profits interest, entities taxed as partnerships can reward employees with equity. Mistakes, however, could cause challenges from taxing authorities.

Tax Clinic

Proposed regulations issued on retirement catch-up contributions

IC-DISC commission payment provisions

The role of REITs for foreign investors in US real estate

Signing partnerships’ returns and other tax documents

Practical considerations for taxpayers and advisers following Loper Bright and Corner Post