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.
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TOPICS / CORPORATIONS
Deductions
Commitment fees related to revolving credit agreement
The IRS released advice that concluded that an accrual-based taxpayer was entitled to deduct quarterly commitment fees paid related to its
revolving credit agreement.
More positive news for taxpayers with pilot model supply expenses
Recent events should give taxpayers greater confidence to include pilot model expenses as Sec. 74 expenses and R&D supply costs.
Sec. 162(m) grandfather rule can apply to more than just performance-based compensation
The Sec. 162(m) grandfather rule provides multiple opportunities outside of the exemption for performance-based compensation.
IRS says no to dividends-received deduction related to ETF shares
The IRS concluded that a derivative that referenced a stock index was “substantially similar or related
property” to the stock of an exchange-traded fund that held the components of the index.
IRS issues chief counsel advice on success-based fees
The IRS concluded that a taxpayer was required to capitalize 100% of an investment banking fee because it failed to satisfy the documentation requirement for success-based fees under Regs. Sec. 1.263(a)-5.
Certain moving expenses incurred in 2017 not subject to withholding and employment tax in 2018
Employer reimbursements made in 2018 of qualified moving expenses incurred prior to 2018 in connection with a move that occurred prior to Jan. 1, 2018, may be excluded from employees’ wages and gross income despite the suspension of the exclusion for tax years 2018 through 2025.
IRS clarifies deductibility of business meals
The IRS issued guidance on the deductibility of meal and entertainment expenses after the modification of Sec. 274 by the TCJA.
Proposed regs. outline new business interest expense limitation
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.
IRS defines covered employees and grandfathered employment contracts under Sec. 162(m)
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.
Tax pitfalls of owning a marijuana business
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.
Meals continue to be deductible under new IRS guidance
The IRS issued guidance on the deductibility of meal and entertainment expenses after the modification of Sec. 274 by the TCJA.
Revisiting the application of Sec. 280G on partnerships and LLCs
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.
Timing of the tax deduction for worthless intangibles
The challenge taxpayers frequently face is determining the date of sale, abandonment, or worthlessness.
IRS provides initial guidance on new Sec. 162(m)
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.
Foreign-derived intangible income deduction: Tax reform’s overlooked new benefit for U.S. corporate exporters
One new opportunity created by the TCJA is the foreign-derived intangible income deduction in Sec. 250(a).
How the 2017 tax overhaul changed Sec. 162(m)
This article discusses how the TCJA altered corporations’ responsibilities and the potential compensation implications.
IRS issues first guidance on new business interest limitation
The IRS issues guidance on business interest limitation under the new tax act.
Deducting deferred bonuses
Numerous rules and restrictions govern the timing
of deductibility of bonuses accrued in one year and paid in another.
Application of Sec. 199A deduction to health care
While businesses involving the performance of services in the health care field were generally understood as not qualifying for the Sec. 199A deduction, further analysis could provide a favorable result.
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.
