Tax News & Opinion
May 10, 2019
In Rev. Rul. 2019-13, the IRS ruled that a distribution to the sole shareholder of a C corporation was partly a recovery of the former S corporation’s accumulated adjustments account (AAA) and a taxable dividend for the remaining distribution.
The company involved was originally a C corp…
May 09, 2019
The IRS intends to revise its regulations to make them consistent with the recent statutory changes to the automobile price inflation adjustment in Sec. 280F(d)(7), which affect the vehicle value that applies when valuing employees’ personal use of employer-provided vehicles (Notice 2019…
May 08, 2019
The IRS issued proposed regulations (REG-105476-18) on the operation of new Sec. 1446(f), which requires withholding on the transfer of a partnership interest described in Sec. 864(c)(8) (gain or loss of foreign persons from the sale or exchange of certain partnership interests). Sec. 1446(f) …
April 17, 2019
The IRS issued more proposed regulations (REG-120186-18) on Sec. 1400Z-2, a new provision added by the law known as the Tax Cuts and Jobs Act, P.L. 115-97, that establishes qualified opportunity funds (QOFs) to encourage investments in low-income communities. Sec. 1400Z-2 offers three federal …
April 17, 2019
On Tuesday, the U.S. Supreme Court heard oral arguments in the case of North Carolina Dep’t of Rev. v. Kimberley Rice Kaestner 1992 Family Trust, No. 18-457 (U.S.). The case involves a North Carolina statute (N.C. Gen. Stat. §105-160.2) that allows a trust to be taxed sole…
April 11, 2019
Professional sports teams that trade player contracts or draft picks will not have to value the contracts or draft picks when determining their gain or loss on the trade under a safe harbor issued by the IRS on Thursday (Rev. Proc. 2019-18). The guidance allows teams to treat certain personnel…
April 11, 2019
On April 9, Annette Nellen, the chair of the AICPA Tax Executive Committee, sent a letter to Treasury and to the IRS Chief Counsel’s Office asking for additional guidance on the Sec. 199A deduction for qualified business income (QBI) beyond the corrected final regulations (T.D. 9847) and…
March 29, 2019
Rev. Rul. 2019-11, issued Friday, the IRS addressed how the long-standing tax benefit rule interacts with the new $10,000 limit on deductions of state and local taxes to determine the portion of any state or local tax refund that must be included on the taxpayer's federal income tax return.
Se…
March 27, 2019
Beginning May 13, the IRS will accept employer identification number (EIN) applications only from individual taxpayers who have either a Social Security number or an individual taxpayer identification number as the responsible party on the EIN application, the IRS announced on Wednesday (IR-20…
March 26, 2019
The IRS on Tuesday issued guidance regarding the amount of the Sec. 6707A penalty for failure to disclose reportable transaction information (T.D. 9853). Tuesday’s final regulations adopt a definition of “decrease in tax” for Sec. 6707A purposes and provide guidance for situa…