News

Final regs. eliminate estate and gift tax clawback

The IRS issued final regulations that reconcile the current higher exclusion for the estate and gift tax unified credit amount in effect under the law known as the Tax Cuts and Jobs Act with the lower unified credit, which is scheduled to go into effect in 2026, eliminating a possible future clawback of the higher exclusion amount.

CFC downward attributions get safe harbors

U.S. shareholders who own stock in foreign corporations were given a safe harbor by the IRS, making it easier for them to establish that they are not shareholders in a controlled foreign corporation, or CFC.

IRS issues 2019 to 2020 per-diem rates for traveling away from home

The IRS issued its annual notice specifying the special per-diem rates, including the transportation industry meal and incidental expenses rates, the rate for the incidental-expenses-only deduction, and the rates and list of high-cost localities for purposes of the high-low substantiation method.

Safe harbor allows QBI deduction for rental real estate businesses

The IRS issued a revenue procedure describing the requirements taxpayers have to meet to be a rental real estate business that qualifies for the safe harbor to be treated as a trade or business in order to qualify for the Sec. 199A qualified business income deduction.

Final regs. loosen 401(k) hardship distribution requirements

The IRS issued final regulations governing hardship distributions from Sec. 401(k) plans, eliminating the requirements that participants obtain a loan from the plan if available and that suspend participants’ ability to make contributions to the plans for six months after taking a hardship distribution.

Newsletter Articles

TAX REFORM

Traps for the unwary: Tax Cuts and Jobs Act changes

By now many of us are familiar with the various provisions of the law known as the Tax Cuts and Jobs Act (TCJA), P.L. 115-97. Here is a list of changes together with (perhaps) unexpected nuances.

DEDUCTIONS

Qualified business income deduction regs. and other guidance issued

The package includes final regulations, guidance on how to calculate W-2 wages, a safe-harbor rule for rental real estate businesses, and new proposed rules on the treatment of previously suspended losses.