Inflation Adjustments Impact Qualified Small Businesses

Summary

Various provisions of the Internal Revenue Code that are tied to specified dollar amounts provide that those dollar amounts are to be increased for inflation. Provisions of interest in the accounting methods realm include the increases to the threshold to be considered a small business taxpayer, which determines whether certain entities...

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Family Office Structuring in Light of Lender Ruling

Recent court rulings and tax reform legislation has an impact on family office expense deduction. The lack of definition and bright-line test determining “trade or business activities” means that we must carefully consider the distinct facts and circumstances of each family office. Background Tax reform legislation on December 22, 2017,...
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Proposed Rules Explain 199A Deduction for Cooperatives & Their Patrons

Taxpayers may rely on two new pieces of IRS guidance for applying the Code Sec. 199A deduction to cooperatives and their patrons:

  1. Proposed regulations provide detailed rules for coop patrons and specified cooperatives to calculate the deduction.
  2. A proposed revenue procedure provides three methods for specified cooperatives to calculate W-2...
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IRS Extends Passthrough Deduction to Real Estate Rental Activities

New IRS guidance fills in several more pieces of the Code Sec. 199A passthrough deduction puzzle. Taxpayers can generally rely on all of these new final and proposed rules.

Final Regulations

The final regulations in T.D. 98xx_1 largely adopt the proposed regulations in NPRM REG-107892-18 (August 16, 2018), but with substantial modifications.

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Guidance Issued on Nondeductible Portion of Parking Fringe Expenses

The IRS has provided guidance and examples for calculating the nondeductible portion of parking expenses. In addition, the IRS has provided guidance to tax-exempt organizations to help such organizations determine how unrelated business taxable income (UBTI) will be increased by the nondeductible amount of such fringe benefit expenses paid or...

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Proposed Regulations Provided for Code Sec. 163(j) Limit

The IRS has proposed regulations on the limitation on the business interest expense deduction under Code Sec. 163(j), as amended by the Tax Cuts and Jobs Act (TCJA) ( P.L. 115-97). The IRS also has issued a safe harbor that allows taxpayers to treat certain infrastructure trades or businesses as real property trades or businesses solely for...

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Regulations to be Issued on Controlled Foreign Corporations’ Previously Taxed Earnings and Profits

The IRS and the Treasury intend to provide regulations that will address issues affecting foreign corporations with previously taxed earnings and profits (PTEP). The regulations are in response to changes made by the Tax Cuts and Jobs Act (TCJA) (P.L. 115-97), and are intended to include rules for:

  • the maintenance of PTEP in annual accounts and...
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WHAT TO EXPECT ON YOUR FIRST EMPLOYEE BENEFIT PLAN AUDIT

Growing beyond 100 employees is an important landmark in a company’s history. While companies may view crossing this threshold as cause for celebration, the Department of Labor (DOL) may view it as a trigger for increased scrutiny of your employee benefit plan. Certain employee benefit plans with 100 or more eligible participants may be...
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HOW TAX REFORM COULD AFFECT ESOP VALUATIONS

The Tax Cuts and Jobs Act of 2017 (TCJA) was the most sweeping change to the tax code since the mid-1980s. There were only a few provisions in the law that apply to employee stock ownership plans; the reduction of corporate taxes, in particular, will have a significant impact on stock valuations in these types of defined contribution plans. As...

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Wolters Kluwer Interview: The New Code Sec. 199A Passthrough Deduction & Proposed Regulations

Last year’s Tax Reform created a new 20-percent deduction of qualified business income for passthrough entities, subject to certain limitations. The Tax Cuts and Jobs Act (TCJA) ( P.L. 115-97) created the new Code Sec. 199A passthrough deduction for noncorporate taxpayers, effective for tax years beginning after December 31, 2017. However, the...

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