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.
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TOPICS / CORPORATIONS
Deductions
GILTI rules address income subject to high foreign tax rate
The IRS issued final regulations under the global intangible low-taxed income (GILTI) rules on the treatment of income subject to a high rate of foreign tax. At the same time, the IRS issued proposed rules conforming the GILTI high-tax exception rules with the Subpart F high-tax exception.
IRS says PPP expenses nondeductible, but AICPA disagrees
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.
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.
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.
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.
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.
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.
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.
Regs. governing $1 million compensation limits are proposed
The IRS issued proposed regulations on the Sec. 162(m) $1 million limit on executive compensation paid by certain publicly held corporations.
Proposed regs. issued on meal and entertainment expense deductions
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.
Tax Court shoots down finder’s fee deduction
A company acquired by another company cannot take a deduction for a fee from the acquisition transaction that it paid on behalf of the acquiring company.
The business meal expense deduction after the TCJA
This article explores the competing perspectives and discusses the IRS’s interim guidance on the deductibility of business meals.
Proposed regs. would govern Sec. 162(m) executive compensation limits
The IRS issued proposed regulations on the Sec. 162(m) $1 million limit on executive compensation paid by certain publicly held corporations.
IRS releases guidance on treatment of transaction costs
The IRS’s Large Business and International
Division released “Examining a Transaction
Costs Issue” regarding the treatment of transaction costs incurred in certain business transactions.
Foreign-derived intangible income guidance addresses many open questions
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.
W-2 methods proposed for Sec. 199A(g) deduction by agricultural co-ops
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.
Taxation of sexual harassment settlements post-TCJA
Because of the considerable tax consequences, the new law will encourage plaintiffs and defendants to refrain from including a nondisclosure agreement in their sexual harassment settlements.
Potential pitfalls of charitable contribution substantiation and reporting
Failure to properly complete all required fields on Form 8283, including the donor’s cost or other basis, could jeopardize the entire deduction with respect to the donated property.
employee benefits & pensions
Profits interests: The most tax-efficient equity grant to employees
By granting them a profits interest, entities taxed as partnerships can reward employees with equity. Mistakes, however, could cause challenges from taxing authorities.
