This item clarifies the various categories of income inclusions a U.S. shareholder of a CFC may need to consider to the extent of its current-year earnings and profits or deficits and how to properly report and track any foreign inclusions related to E&P.
Results for ""TCJA""
Many questions remain with respect to the deductibility at the federal level of state income tax payments made by passthrough entities under new state tax regimes enacted to ameliorate the effect of the cap for individuals on the deduction of state and local taxes.
In this first installment of an annual update on trust, estate, and gift taxation, the topics include estate tax closing letters, the basic exclusion amount, estate debts and expenses, and extending the time to elect portability.
The unique characteristics of this new asset class present a host of additional issues unique to digital asset transactions.
This item summarizes the impact of two sets of proposed regulations issued by Treasury in early 2022.
For certain partners, the presumed preference for receiving a distributive share of income (including a priority profit allocation) may need further evaluation to determine how it coordinates with various international tax provisions.
Modifications to Sec. 174 may affect other areas of taxation which must also be reflected in financial statements and estimated tax payments.
This item summarizes the TCJA’s changes to Sec. 451 and discusses the opportunities the December 2020 final regulations may provide to reduce income acceleration.
This article discusses a strategy to allow more interest to be deducted under the limitation involving the strategic adoption of FASB Accounting Standards Codification Topic 606, Revenue From Contracts With Customers.
The US Government Accountability Office found disparities in the distribution of some tax items, but notes impediments to knowing taxpayers’ race, ethnicity, and sex.
The $10,000 limitation on deducting state and local taxes stands after the Supreme Court refused to review a long-running lawsuit by New York and three other states.
Many of the changes provide a reduction of overall state taxes beginning in 2022 and forward.
Fiscal 2023 tax provisions also would increase IRS funding, encourage domestic business investments, and repeal many fossil fuel tax preferences.
The federal opportunity zone program creates jobs and improves communities, and the tax benefits for investors remain substantial.
This semiannual update covers recent federal tax developments involving individuals, highlighting noteworthy IRS guidance and decisions of the Tax Court and other courts, as well as tax changes made by legislation.
The discussion covers developments in the determination of partners and partnerships, gain on disposal of partnership interests, partnership audits, and basis adjustments.
taxable income with recognized losses. This item focuses on legislative developments in California, Illinois, and Kansas, as well as judicial decisions in Pennsylvania and New Jersey, that highlight imposed limitations on NOL usage.
During 2021, the IRS issued taxpayer-favorable procedures allowing certain taxpayers that have made the real property trade or business election under Sec. 163(j)(7)(B) with residential rental property to depreciate such property using the shorter 30-yearrecovery period, using ADS, and certain other taxpayers with qualified residential living facilities to be eligible for the real property trade or business election.
This item summarizes IRS guidance on cryptoassets, including the latest releases from the Service.
Beginning a detailed analysis early will allow taxpayers the time and flexibility to make those choices and to perform complex computations or make required tax filings.