The IRS issued proposed regulations on the operation of new Sec. 1446(f), which requires withholding on the transfer of a partnership interest described in Sec. 864(c)(8) (gain or loss of foreign persons from the sale or exchange of certain partnership interests).
News
More proposed regs. on qualified opportunity funds issued
The regulations define the term “substantially all,” the definition of which was reserved in the earlier proposed regulations issued in October 2018.
Can a state tax a trust based on the beneficiary’s residency?
The U.S. Supreme Court heard oral arguments in a case that will decide whether states can tax trusts based solely on the fact that a trust beneficiary lives in the state.
Safe harbor issued for valuing pro sports trades
The IRS will permit professional sports teams that trade player contracts to recognize zero gain if both parties to the exchange adopt the safe harbor and do not exchange cash.
AICPA asks government to issue more QBI deduction guidance
The AICPA asked Treasury and the IRS to issue additional guidance on Sec. 199A beyond the recently finalized regulations and a proposed revenue procedure in the form of a notice on a safe harbor for rental real estate.
Tax treatment of state and local tax refunds clarified
The IRS issued guidance on the tax treatment of state and local refunds now that taxpayers are limited to a $10,000 deduction on their individual tax returns.
Procedure for obtaining EINs to change May 13
Beginning May 13, the IRS will accept employer identification number (EIN) applications only from individual taxpayers who have either a Social Security number or an individual taxpayer identification number as the responsible party on the EIN application.
Final rules issued on penalty for nondisclosure of reportable transactions
The IRS issued final regulations under Sec. 6707A, which imposes a penalty on taxpayers who fail to disclose a reportable transaction on their tax returns.
IRS expands relief from underpayment penalty
The IRS announced that it is lowering from 85% to 80% the amount taxpayers are required to have paid in order to escape an underpayment of estimated income tax penalty for 2018.
Proposed rules issued for information reporting for life insurance contract transactions
The IRS proposed regulations under Sec. 6050Y, which governs reporting obligations for reportable policy sales of life insurance contracts and payments of reportable death benefits.
IRS reevaluating active trade or business requirement for spinoffs
The IRS announced that it is reviewing its approach to the active trade or business requirement that must be met for a five-year period for a business to qualify for a tax-free spinoff under Sec. 355 and, as a result, is suspending two revenue rulings, Rev. Ruls. 57-464 and 57-492, in which it previously ruled on the topic.
IRS’s Dirty Dozen scams — 2019 edition
The IRS highlighted the 12 abusive tax schemes it wants taxpayers and tax practitioners to be on the alert for this year. Phishing and scam phone calls were the biggest repeat offenders.
First-year challenges of TCJA implementation require broader penalty relief
Despite generally lower tax bills, many taxpayers are seeing smaller-than-expected refunds — or no refunds at all. And some taxpayers are now subject to underwithholding penalties, despite limited relief from the IRS.
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.
Treasury announces changes to tax regulatory process
The IRS and the Treasury Department announced changes to their policy on issuing temporary regulations, notices of proposed regulations, and other guidance.
Guidance proposed on FDII and GILTI deductions
The IRS issued guidance on determining the amount of the deduction for foreign-derived intangible income (FDII) and global intangible low-taxed income (GILTI) under Sec. 250.
Court upholds IRS PTIN fees
The IRS has authority to charge a user fee for preparer tax identification numbers (PTINs) a federal appeals court held, paving the way for the agency to reinstate the charges for obtaining and renewing a PTIN.
Times have changed; professional standards should, too
The AICPA is revising its Statements on Standards for Tax Services and wants your help.
IRS finalizes centralized partnership audit regulations
The IRS issued final regulations on the centralized partnership audit regime, which generally assesses tax at the partnership level.
State tax law cannot discriminate against federal pensioners, Supreme Court holds
The U.S. Supreme Court held that West Virginia cannot provide a tax exemption to state law enforcement retirees while denying that exemption to federal law enforcement retirees who performed similar jobs.
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