Certified professional employer organizations enter into contracts with employers to be treated as the employer for employment tax purposes and are subject to IRS rules in order to qualify as CPEOs and maintain that status.
Several tax benefits can accrue to taxpayers that make investments in certain low-income communities through qualified opportunity funds. A second round of proposed regulations addresses many outstanding questions about this new vehicle for taxpayer-friendly investing in distressed communities.
This item discusses the clarifications and questions that were answered with the issuance of a second set of proposed regulations on May 1, 2019.
Shareholders and their advisers should be prepared to verify the validity of the S election when the decision is made to begin marketing the company for sale.
Sec. 250 allows domestic corporations a deduction for their “foreign-derived intangible income.” Proposed regulations that were issued earlier this year answer many outstanding questions regarding the calculation of this new deduction but also include documentation requirements that may prove onerous for some taxpayers.
This discussion explores the allocation of E&P in a distribution to which Sec. 355 applies.
This item discusses special return due-date rules for a target corporation’s short tax year when it joins a consolidated group.
Before transferring Sec. 987 QBUs to related domestic or foreign parties, practitioners should consider the tax implications of the May final regulations.
The regulations define the term “substantially all,” the definition of which was reserved in the earlier proposed regulations issued in October 2018.
This discussion focuses on the GILTI and BEAT implications for the benefit received by a U.S. corporation reporting a worthless stock deduction under Sec. 165(g) for a CFC’s stock.
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.
Rev. Proc. 2019-18 allows teams that fit within the safe harbor to treat the contracts as having a zero value for determining gain or loss.
The IRS issued methods for calculating W-2 wages for the Sec. 199A(g) deduction for agricultural and horticultural cooperatives, similar to the former Sec. 199 domestic production activities deduction.
The Ninth Circuit Court of Appeals reversed a Tax Court decision that had held that a cost-sharing regulation that required allocation of stock-based compensation was invalid.
The TCJA made a significant cange to the tax treatment of grants received from governmental entities, including location incentives for relocating or expanding existing facilities.
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.
Banks, hotel groups, large retailers, utilities, and car rental companies may be eligible for refunds of federal excise tax paid when purchasing frequent flyer miles from domestic airlines to use in reward and loyalty programs.
Review the various approaches states use to account for the GILTI and FDII regimes introduced by the TCJA.
Converting a C corporation to a limited liability company can sometimes be beneficial, but the tax consequences must be planned for.
Certified professional employer organizations (CPEOs) enter into contracts with employers to be treated as the employer for employment tax purposes and are subject to IRS rules in order to qualify as CPEOs and maintain that status.