The TCJA amended Sec. 461 to include a subsection (l), which disallows excess business losses of noncorporate taxpayers if the amount of the loss is in excess of $250,000 ($500,000 in the case of a joint return).
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TOPICS / INDIVIDUALS
Income
Opportunities beckon in new qualified opportunity zones
With their prospects for deferral or even exclusion of gains from certain investments in them, the newly created qualified opportunity zones offer an intriguing tax planning option for investors and a potential boon for distressed communities.
More proposed regs. on qualified opportunity funds issued
The regulations define the term “substantially all,” the definition of which was reserved in the earlier proposed regulations issued in October 2018.
Qualified transportation fringe benefit and loss of deduction under tax reform
The IRS released Notice 2018-99 providing further guidance on determining the loss of the deduction under certain qualified parking fact patterns.
Payments under broker agreement characterized as long-term capital gains
Payments made to a taxpayer under a broker agreement were payments for the rights to a patent owned by the taxpayer that were properly classified as long-term capital gains.
Involuntary conversion of a principal residence
Every year, many taxpayers’ principal residences are destroyed or taken through condemnation by the government. This article discusses the application of Secs. 121 and 1033 when a taxpayer suffers an involuntary conversion of a principal residence.
Traps for the unwary: Tax Cuts and Jobs Act changes
This article lists the changes together, along with some unexpected nuances.
Opportunities beckon in new qualified opportunity zones
With their prospects for deferral or even exclusion of gains from certain investments in them, the newly created qualified opportunity zones offer an intriguing tax planning option for investors and a potential boon for distressed communities.
Private company equity grant rules are issued
The IRS issued initial guidance on the application of Sec. 83(i), which allows certain employees to defer recognition of income attributable to the receipt or vesting of qualified stock.
IRS issues guidance on disallowance of deductions for parking fringe benefits
The IRS issued guidance outlining how to determine the amount of parking expense that is nondeductible under Sec. 274(a)(4) when employers provide parking for their employees.
Individual tax report
This semiannual update on current developments in the area of individual taxation includes a number of cases on material participation, hobby losses, charitable contributions, the Sec. 199A regulations, and several other important areas.
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.
Modification of variable prepaid forward contracts triggers gain realization
A Second Circuit decision may affect the analysis
of whether the modification of a derivative triggers gain or loss.
Economic benefits of life insurance premium payments are not includible in income
Economic benefits from an S corporation’s payment
of a premium on a life insurance policy were not includible in the shareholder/employee’s income.
IRS explains disallowance of qualified transportation fringe benefits for parking
The IRS issued guidance outlining how to determine the amount of parking expense that is nondeductible under Sec. 274(a)(4) when employers provide parking for their employees.
Initial guidance issued on Sec. 83(i) deferral election for private company equity grants
The IRS issued initial guidance on the application of Sec. 83(i), which allows certain employees to defer recognition of income attributable to the receipt or vesting of qualified stock.
Tax reform: Individual taxpayers and the Sec. 962 election
The new “repatriation tax” under the TCJA may cause individual partners and shareholders of flowthrough entities to obtain a deferred tax rate benefit by making this election.
Sale of improved land: Capital or ordinary gain?
In certain situations, a taxpayer may be able to
claim capital gain treatment, even if the taxpayer
subdivides the real property into lots and actively tries to sell the parcels.
Five types of interest expense, three sets of new rules
This article provides an overview of the rules that apply to each type of interest after the passage of the TCJA.
Damages and interest from stray voltage suit are ordinary income
A jury award of tort damages plus interest was ordinary income, and the interest award was subject to self-employment tax.
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.
