This article examines the calculation of the UBIA of qualified property; offers guidance on special situations such as like-kind exchanges and the Sec. 754 election; and presents planning opportunities to maximize the UBIA of qualified property.
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TOPICS
Individuals
When do payments to clergy move from gifts to remuneration?
Are gifts to clergy taxable income for federal income tax purposes? The answer involves a careful consideration of the surrounding circumstances.
Taxpayers may deduct casualty losses in prior years
The IRS finalized regulations permitting taxpayers to deduct disaster losses in the prior tax year and removed the related temporary regulations that were issued in 2016.
Health savings accounts can save taxpayers money
Combined with higher standard deductions under the TCJA, most people do not have enough medical expenses and other qualifying itemized deductions to exceed the standard deduction.
IRS clarifies the tax treatment of cryptocurrency ‘hard forks’ and ‘airdrops’
The IRS ruled that a taxpayer does not have gross income as a result of a hard fork of a cryptocurrency if the taxpayer does not receive units of a new cryptocurrency, but does have gross income as a result of an airdrop of new cryptocurrency after a hard fork if the taxpayer receives units of the new cryptocurrency.
Pitfalls and treasures of the QBI deduction
The QBI deduction raises new considerations for retirement contributions and accounting method changes for small businesses.
The TCJA: Double taxation for US citizens living abroad
Individuals, who are not afforded the benefit of using indirect foreign tax credits, are unable to reduce their Sec. 965 liability with foreign taxes generated at the foreign company level.
Like-kind exchanges and personal property
Because of a change in the TCJA, disposal of personal property and its exchange with other personal property of like kind is now a taxable event.
IRS issues 2019 to 2020 per-diem rates for traveling away from home
The IRS issued its annual notice specifying the special per-diem rates, including the transportation industry meal and incidental expenses rates, the rate for the incidental-expenses-only deduction, and the rates and list of high-cost localities for purposes of the high-low substantiation method.
Safe harbor allows QBI deduction for rental real estate businesses
The IRS issued a revenue procedure describing the requirements taxpayers have to meet to be a rental real estate business that qualifies for the safe harbor to be treated as a trade or business in order to qualify for the Sec. 199A qualified business income deduction.
Final regs. loosen 401(k) hardship distribution requirements
The IRS issued final regulations governing hardship distributions from Sec. 401(k) plans, eliminating the requirements that participants obtain a loan from the plan if available and that suspend participants’ ability to make contributions to the plans for six months after taking a hardship distribution.
IRS offers expatriate tax relief
The IRS announced procedures to allow certain individuals who have renounced their US citizenship to get into compliance with their U.S. tax obligations and obtain relief for back taxes.
HRAs can be integrated with individual health plans
The IRS issued final regulations on health reimbursement arrangements, which may be offered to individuals as individual coverage HRAs and integrated into health insurance plans.
Taxpayer can deduct settlement payment to ex-husband
The Eleventh Circuit holds a taxpayer is entitled to a deduction under Sec. 1341 for a payment made
to reimburse her ex-spouse for a portion of a settlement in an excess-compensation lawsuit.
Limiting business interest expense
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.
Current developments in individual taxation
This article is a semiannual review of recent developments in individual federal taxation, covering cases, rulings, and guidance on a variety of topics.
The solar energy credit: Where to draw the line?
To determine the IRS’s likely treatment, an analysis is necessary of two Code sections that address energy credits: Sec. 25D and Sec. 48.
Proposed regs. govern maximum automobile values
The IRS issued proposed rules that provide maximum automobile values for the cents-per-mile and fleet-average valuation rules used to determine the amount to include in an employee’s gross income for personal use of an employer-provided vehicle.
A cautionary tale of opportunity zone deferrals
This article provides an overview of the rules for determining the 180-day period to qualify for the full benefits of a qualified opportunity zone investment.
Alimony tax gap swells to $3.2 billion, TIGTA finds
Discrepancies between the amount of alimony deducted by payers and reported as income by its recipients increased by 38% in six years, the Treasury Inspector General for Tax Administration reported.
INDIVIDUALS
Current Developments in Taxation of Individuals: Part 1
This update surveys recent federal tax developments involving individuals, including court cases, rulings, and guidance issued during the six months ending October 2025.
