IRS Issues Final Transition Tax Regulations
On January 15, 2019, the IRS and Treasury released final regulations on the section 965 transition tax. The final regulations largely adopt the basic approach and the structure of the proposed regulations (REG-104226-18) issued on August 9, 2018 but with some changes, including modifications to the election to reallocate basis to reflect the offset of positive earnings with deficits...Joint Committee on Taxation Releases Blue Book of TCJA
The General Explanation of Public Law 115-97, prepared by the staff of the Joint Committee on Taxation in consultation with the staffs of the House Committee on Ways and Means, the Senate Committee on Finance, and the Treasury Department’s Office of Tax Policy, was released this week. The explanation provides a discussion of the Tax Cuts and Jobs Act (TCJA) including a description of...OMB Receives Final and Proposed Section 199A Regulations
Posted on Dec 17, 2018 in Individual Taxation
The Office of Management and Budget (OMB) received the proposed and final regulations regarding the new section 199A pass-through deduction regime on December 13 and 14. The proposed regulations focus on regulated investment company-specific guidelines while the final regulations follow up on the proposed pass-through deduction rules released in August. The regulations are not marked...
IRS Releases Priority Guidance Plan for 2018-2019
Posted on Nov 9, 2018 in Individual Taxation, International Tax, Pass-through Taxation, Tax Accounting
On November 8, the IRS and Treasury Department released their priority guidance plan (PGP) for 2018-2019, which includes a number of projects concerning the implementation of the Tax Cuts and Jobs Act. Planned projects include finalizing regulations under sections 199A (the 20% deduction for qualifying business income) and 951A (global intangible low-taxed income) and issuing...
OIRA Receives Proposed Section 163(j) Regulations for Review
Posted on Oct 26, 2018 in Individual Taxation, International Tax, News, Pass-through Taxation, Tax Accounting
The Office of Information and Regulatory Affairs (OIRA) received draft proposed regulations under section 163(j), addressing the limitation on business interest deductions, on October 25, according to the Office of Management and Budget’s website. As amended by the Tax Cuts and Jobs Act (TCJA), section 163(j) generally limits business interest expense deductions to the sum of business...
IRS Releases Opportunity Zone Guidance
Posted on Oct 19, 2018 in Individual Taxation, Pass-through Taxation
On October 19, 2018, the IRS released proposed regulations (REG-115420-18) concerning opportunity zones (sections 1400Z-1 and 1400Z-2). Opportunity zones were created by the Tax Cuts and Jobs Act and allow tax benefits for investments in low-income communities, through what are termed qualified opportunity funds. Among other items, the proposed regulations provide taxpayers with...
Treasury Guidance May Shield Opportunity Zone Transfers From Capital Gains Tax
Posted on Oct 12, 2018 in Individual Taxation
In a conversation with reporters, Senator Tim Scott, who helped draft the Tax Cuts and Jobs Act, stated that he has encouraged Treasury and the IRS to adopt guidance that would allow investors to transfer funds between opportunity zones without subjecting the transfers to federal capital gains tax. His comments are in reference to new section 1400Z-2 of the Code, which was added by the...
IRS Provides Interim Guidance on Expenses for Business Meals
Posted on Oct 3, 2018 in Individual Taxation
The Treasury Department and IRS issued Notice 2018-76, offering interim guidance under section 274 of the Code. The guidance provides that taxpayers may treat certain business meal expenses as non-entertainment and may continue to deduct 50 percent of food and beverage expenses associated with operating their business or trade, so long as the expenses are not extravagant and the...
House Approves Three New Tax Bills
Posted on Sep 28, 2018 in Individual Taxation, News
On September 27, 2018, the House approved two bills that are part of a second package of tax law changes advanced by House Republicans (“Tax Reform 2.0”). The first bill would create universal savings accounts, expand the utility of section 529 education savings plans, and make the offering of employee retirement plans more accessible for small businesses. The second bill would provide...