Disallowance of deduction for FDIC premiums under Sec. 162(r)
No deduction may be claimed for FDIC premiums paid or accrued by taxpayers with total consolidated assets of $50 billion or greater.
Corporations
Elective capitalization as a TCJA planning tool
Taxpayers whose overall tax position in a given year would benefit from accelerating gross income or from converting current deductions into capital expenditures should consider the elective capitalization provisions of Sec. 266.
IRS issues Form 7200 for advance payment of employer tax credits, explains employee retention credit
The IRS issued a new form and instructions for employers to use to obtain advance payments of three tax credits that were created to help businesses cope with the coronavirus pandemic.
Hedging transactions: Timing of gain or loss
While the U.S. federal income tax rules generally provide comprehensive instruction on tax hedging transactions, ambiguity remains regarding the timing for transactions intended to hedge anticipated, but unfulfilled, transactions.
Deduction limitations of Sec. 162(m) to compensation paid by partnerships in Up-C and UPREIT structures
Proposed regulations change the paradigm for the tax treatment of compensation paid by a partnership situated below a publicly held corporation in an Up-C or UPREIT structure.
Final regs. clarify when interest in corporation is stock vs. debt
The IRS has issued final regulations addressing when certain related-party interests in corporations should be treated as stock vs. debt.
Proposed rules govern deductions and reporting for restitution
The IRS issued regulations explaining the allowance of deductions for certain fines and penalties under Sec. 162(f) as amended by the law known as the Tax Cuts and Jobs Act.
AICPA challenging nondeductibility of PPP-related expenses
The IRS issued guidance clarifying that a deduction is disallowed for expenses for payroll costs, mortgage interest, rent, utilities, and other interest on debt obligations to the extent they are being reimbursed by loans forgiven under the Paycheck Protection Program.
Meal expenses still 50% deductible under proposed regs.
The IRS issued proposed rules clarifying that taxpayers may generally continue to deduct 50% of the food and beverage expenses associated with operating their trade or business, despite changes to the meal and entertainment expense deduction under Sec. 274.
Do a business’s charitable contributions reduce its QBI deduction?
A search of T.D. 9847 yields no discussion of whether the deduction for charitable contributions should be included in the computation of QBI.
Puerto Rico: A permanent tax deferral in a GILTI world?
Under the right set of circumstances, there may be a significant opportunity for tax savings in Puerto Rico.
Classifying business entities under the check-the-box regulations
An entity that is recognized for federal tax purposes as an entity separate from its owners can be classified as one of several entity types, but the available classification options depend greatly on state law and the number of owners or members.
Employer tax credits form, employee retention credit guidance posted
The IRS issued a new form and instructions for employers to use to obtain advance payments of three tax credits that were created to help businesses cope with the coronavirus pandemic.
Compensation and benefit deductions when domesticating a CFC
This item briefly discusses some risk areas for newly domesticated CFCs to help advisers spot issues for clients.
IRS regulations update maximum vehicle values
The IRS finalized the rules for maximum vehicle values under the cents-per-mile valuation rule and the fleet-average valuation rule after the TCJA increased those values to $50,000, adjusted for inflation.
Coronavirus paid sick leave and family leave guidance issued
The IRS issues rules to implement paid sick and child care leave credits enacted in response to the pandemic.
CARES Act tax provisions aim to stabilize pandemic-ravaged economy
The $2 trillion stimulus bill, which passed the Senate by a 96-0 vote late on Wednesday, contains many tax provisions. Here’s a look at the tax items, which range from credits to temporary changes to retirement plan rules.
Practitioners seek further clarity on tax filing, payment delay
Practitioners welcomed the IRS’s deferral of income tax returns and payments due April 15 for another 90 days but have many questions about related issues.
IRS provides guidance for April 15 filing delay
The IRS announced the postponement of the April 15 federal income tax filing deadline until July 15. Friday’s notice expands on earlier guidance that had only postponed tax payments but not the filing deadline.
Tax filing deadline moving to July 15, Treasury secretary announces
Treasury Secretary Steven Mnuchin announced that taxpayers will have until July 15 to file their tax returns, a change from the guidance announced by the IRS earlier.
