Taxation of sexual harassment settlements post-TCJA
Because of the considerable tax consequences, the new law will encourage plaintiffs and defendants to refrain from including a nondisclosure agreement in their sexual harassment settlements.
Individual Income Taxation
IRS changes maximum-vehicle-value rule
The IRS revised its maximum-vehicle-value rule for personal use of an employer-provided vehicle for 2019 for both the cents-per-mile rule and the fleet-average-valuation rule.
Simplifying the Rube Goldberg tax code
Similar to a Rube Goldberg contraption, the Internal Revenue Code is needlessly complex. Here are a few ideas for simplification and a request for readers to suggest others.
REIT dividends and PTP income under Prop. Regs. Sec. 1.199A-3(d)
Dividends from REITs and income from PTPs generally qualify for the 20% deduction.
Flip the tax return with a professor-prepared tax return
Now that IRS forms have been created to reflect the changes of the TCJA, a professor-prepared tax return assignment gives faculty an opportunity to introduce their students to new tax law complexities.
New limitation on excess business losses
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).
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.
Computing qualified W-2 wages for Sec. 199A purposes
Computing total W-2 wages under Sec. 199A appears daunting, in part because three possible methods are available to do so.
Key tax reform provisions affecting sports franchises
This discussion focuses on two notable business provisions in the TCJA affecting sports franchises: new like-kind exchange provisions under Sec. 1031 and the QBI deduction under Sec. 199A.
Sec. 199A and the aggregation of trades or businesses
Aggregation may allow a taxpayer to claim a greater QBI deduction than if the wages and capital limitation was applied separately.
Minimizing federal income tax on trusts under the TCJA
The disparate tax treatment between trusts and individuals has grown even more pronounced than it was before the TCJA was enacted.
Has the TCJA changed the definition of a dependent for children with special needs?
This article provides an overview of the rules defining a dependent and addresses the issue of a child’s receipt of Supplemental Security Income.
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.
Tax consequences for professional athletes in 2018
Proper advance planning is imperative to maximize the benefits of the TCJA provisions.
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.
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.
New proposed regulations on Sec. 199A
The IRS released new proposed regulations on the treatment under Sec. 199A of previously suspended losses, “Sec. 199A dividends” paid by a RIC, and the treatment of amounts received from split-interest trusts and CRTs.
Final regulations on Sec. 199A issued
The IRS issued final regulations on the QBI deduction under Sec. 199A and an anti-avoidance rule under Sec. 643 that will require multiple trusts to be treated as a single trust in certain cases.
Sec. 199A rental real estate activity safe harbor proposed
The IRS issued a proposed revenue procedure that would provide a safe harbor for taxpayers under which a rental real estate enterprise will be treated as a trade or business for purposes of the Sec. 199A deduction.
