The IRS released guidance on the new Sec. 45S tax credit for employers that provide paid medical and family leave.
This item discusses the many tax ramifications of converting.
A terminated S corporation may remain a cash-basis taxpayer if its average gross receipts for the three previous tax periods are less than $25 million.
The IRS issued proposed regulations on the business interest expense limitation in Sec. 163(j), which was amended by the law known as the Tax Cuts and Jobs Act.
Essentially, for federal tax purposes, marijuana businesses pay income taxes on their gross profit instead of their net income because below-the- line deductions are not allowed.
The new lowered corporate tax rate will probably lead to more C corporations and a resulting increase in taxpayers’ interest in the Sec. 1202 100% exclusion on gain from the sale of QSB stock.
The IRS issued guidance regarding amended Sec. 162(m), which limits the allowable deduction for remuneration paid by any publicly held corporation to a covered employee to $1 million.
The shift to a territorial system was designed to help dissuade U.S. companies from moving profits overseas, but it may make the practice more rewarding instead.
The IRS issued guidance on the deductibility of meal and entertainment expenses after the modification of Sec. 274 by the TCJA.
To satisfy the Ilfeld standard, the court noted that there is a presumption that regulations do not permit double deductions for the same loss.
Depending on how a taxpayer’s ownership is structured, the sale of a partnership interest can have a Sec. 280G impact on partners or members that are C corporations.
The IRS issued proposed regulations on the Sec. 965 transition tax that requires U.S. shareholders of deferred foreign income corporations to pay tax on post-1986 deferred income.
This item discusses new trends in states’ conformity with or decoupling from Sec. 965.
the TCJA’s implementation of a hybrid territorial international tax regime mitigates the benefit of the election and may induce taxpayers to not make the election to avoid additional tax liability on the eventual sale of foreign target shares.
Due to TCJA tax rate differential changes, taxpayers may find that the tax benefits of using an IC-DISC no longer outweigh the compliance and maintenance costs.
The exemption to the limitation on business interest under Sec. 163(j) does not apply to a tax shelter prohibited from using the cash-receipts-and-disbursements method of accounting under Sec. 448(a)(3).
The TCJA has given a windfall benefit to foreign investors and developers in U.S. real estate due to the drop in the corporate tax rate from 35% to 21%.
Shareholders can reap several benefits by leasing property to their corporation instead of transferring ownership to the company.
The challenge taxpayers frequently face is determining the date of sale, abandonment, or worthlessness.
The IRS’s LB&I division implemented a major restructuring intended to make better use of IRS resources.