Sec. 163(j) final regs. address the classification of lender fees
This column discusses when loan fees are considered interest expense for purposes of Sec. 163(j)’s interest expense limitation.
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This column discusses when loan fees are considered interest expense for purposes of Sec. 163(j)’s interest expense limitation.
States’ approaches to TCJA and CARES Act conformity will be driven by budget estimates and whether they can follow the reduction to the federal taxable income base while still balancing their budgets.
Right now, some basic tax planning ideas can make a significant difference in reducing income tax, thereby increasing cash flow and even creating tax refund opportunities.
To facilitate the transition away from IBORs and minimize the resulting market disruption, the IRS issued the proposed regulations with an aim of reducing associated tax uncertainty and taxpayer burden.
This discussion provides a high-level overview of the affiliated service group rules.
Under new Sec. 163(j), business interest expense deductions are limited, and a business interest expense that is disallowed in the current year is carried forward to the succeeding tax year.
Recently issued proposed regulations on the transfer of life insurance contracts create significant uncertainty regarding their application to tax-free asset acquisitions.
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.
This discussion highlights the treatment of an “electing real property trade or business” for purposes of the interest expense deduction limitation of Sec. 163(j).
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.
The IRS can take advantage of several rules to ensure related-party transactions do not result in tax evasion or an improper reflection on income.
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.
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).
Some incentives used by state and local governments to attract corporations will now likely be income to the recipient corporation.
The IRS could not recharacterize, under the substance-over-form doctrine, commissions paid by a DISC to two Roth IRAs as dividends..
Real property developed and held by a taxpayer for lease in its leasing business is “real property used in a trade or business.”
Recently issued advice clarifies some of the rules regarding the limitations on the amount of the exclusion.
These transfers are considered a nontaxable contribution of capital by a nonshareholder to the utility.
This item addresses the tax consequences when a nonpublic, financially healthy company renegotiates a debt that was incurred to purchase the company’s assets, and the resulting new debt is contingent on the occurrence of future events.
Proper planning needs to take place to avoid the potential negative tax consequences and complexities of a taxable stock purchase.
TECHNOLOGY
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TAX RELIEF
Quirks spurred by COVID-19 tax relief
This article discusses some procedural and administrative quirks that have emerged with the new tax legislative, regulatory, and procedural guidance related to COVID-19.