Treasury’s Financial Crimes Enforcement Network (FinCEN) made changes to its beneficial ownership information reporting rule in response to comments to a proposed rule.
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Reporting & Filing Requirements
AICPA, others call for a one-year extension of BOI report deadline
In a letter to Treasury’s Financial Crimes Enforcement Network, the AICPA says the additional time will give all businesses a fair and reasonable time frame to become aware of the new and complex rule.
Beneficial ownership information reporting: Right around the corner
Clients should start developing procedures and policies to comply with the new reporting requirement and begin to gather the data that will be necessary.
Proposed regulations update, revise consolidated return regulations
New proposed regulations would update the regulations to reflect 50-plus years of statutory changes, remove regulations and certain transition rules that no longer have practical application, and eliminate obsolete or incorrect terms and cross-references.
AICPA advocates for delay in BOI reporting requirements
Too many businesses are unaware of the beneficial ownership information reporting requirements, which will be a burden for small businesses, the AICPA told Congress.
New stock repurchase excise tax
The Inflation Reduction Act, P.L. 117-169, included a new Sec. 4501 that imposes an excise tax on certain repurchases of stock by publicly traded corporations.
Taxpayers in disaster areas of 3 states have until Oct. 16 to file returns
Taxpayers in most of California and parts of Alabama and Georgia have had their tax filing and payment deadlines further extended to Oct. 16. The postponement covers a wide variety of returns and taxes.
Final regs. expand company e-filing requirements
Final regulations require certain companies to e-file returns for tax years ending on or after Dec. 31, 2023, and lower the e-filing requirement threshold to 10 returns.
90-day deadline for filing Tax Court petition in deficiency case is jurisdictional
Deadline for filing a Tax Court petition in a deficiency case is jurisdictional.
New online portal available for businesses to file Forms 1099
Although available to businesses of any size, the IRS expects the new Information Returns Intake System to be especially useful to small businesses that now file paper Forms 1099.
FinCEN provides time estimates for compiling beneficial ownership details
FinCEN estimates that most companies will have a simple structure that will require 90 minutes per response, but complex entry filings will require much more time.
FinCEN proposes rules about access to beneficial ownership information
Proposed regulations under the Corporate Transparency Act address protocols for access to beneficial owner information by authorized recipients.
Chief Counsel memo clarifies the assessment period in multiyear Sec. 332 liquidations
A recent IRS Chief Counsel memo clarifies the assessment limitation period in multiyear Sec. 332(b) liquidations.
Despite unanswered questions, Tax Court ends long-running case
The Tax Court enters a new decision in a case despite an ambiguous appellate court mandate
Tax practitioner issues related to Sec. 1202 exclusion reporting
The lack of guidance and regulations and the unwillingness of some companies to provide information to shareholders places taxpayers and tax practitioners in a difficult situation.
CFCs: US shareholders’ income inclusions
This item clarifies the various categories of income inclusions a U.S. shareholder of a CFC may need to consider to the extent of its current-year earnings and profits or deficits and how to properly report and track any foreign inclusions related to E&P.
Employer-provided and company-owned vehicles
General or special methods of valuing employer-provided vehicles are available for determining the employer’s and employee’s tax treatment of this fringe benefit.
Gain recognition agreements: US corporation’s transfer of a foreign corporation followed by the foreign corporation’s disposition of its assets
This item discusses the use of GRAs to defer tax on the outbound transfer of stock to a foreign corporation.
Deferral of penalties for failure to timely deposit employment taxes
The IRS determined that a failure to deposit any portion of the federal employment taxes deferred by the CARES Act by the applicable installment due date will result in a penalty.
Voluntary carbon offsets: The evolution of a business expense
This article discusses the disclosure and reporting of VCOs and whether VCOs should be treated as deductible ordinary and necessary business expenses, capitalizable expenses, deductible charitable contributions, or nondeductible expenses.
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.
