In July 2019, the IRS released a Chief Counsel Memorandum explaining how a corporate taxpayer should calculate their charitable contribution deduction and use charitable contribution carryovers when the corporation has current year taxable income — before using prior year net operating loss...
Read MoreCongress gave an early Christmas present to tax-exempt organizations that provide parking for their employees. On December 20, 2019, President Trump signed the Further Consolidated Appropriations Act, 2020, repealing Internal Revenue Code Section 512(a)(7) retroactively as if it were never...
Read MoreWith its winter recess looming, Congress has engaged in a flurry of activity. Most notably, it reached agreement on a massive governmentwide omnibus spending package titled the Further Consolidated Appropriations Act, 2020. Signed by President Trump today, the legislation extends certain income...
Read MoreOn December 19, 2019, the IRS and the U.S. Department of the Treasury released the final regulations on investing in Qualified Opportunity (QO) Funds. The 544-pages of regulations address many areas, just a few of which are listed below:Taxpayers can invest the entire amount of Section 1231 gains...
Read MoreOn December 16, 2019, the Ohio Development Services Agency released the applications for the Ohio Opportunity Zone Tax Credit. Similar to the federal program, the Ohio-specific tax credit provides an incentive for taxpayers to invest in projects in economically distressed areas in Ohio, or &ldquo...
Read MoreOne of the many areas the Tax Cuts and Jobs Act (TCJA) impacts includes the treatment of nonresident aliens as potential current beneficiaries of an Electing Small Business Trust (ESBT). Historically, each potential current beneficiary of an ESBT had to be a U.S. citizen or resident for the trust...
Read MoreThe Tax Relief, Unemployment Insurance Reauthorization and Job Creations Act of 2010 introduced for the first time the concept of portability of the federal estate tax exclusion between spouses. When enacted, it was meant to apply only to estates of decedents dying before January 1, 2013. However...
Read MoreThe IRS has released final regulations and another round of proposed regs for the first-year 100% bonus depreciation deduction. The Tax Cuts and Jobs Act (TCJA) expanded the deduction to 100% if the qualified property is placed in service through 2022, with the amount dropping each subsequent...
Read MoreEarlier this year, the IRS published a proposed safe harbor giving owners of certain rental real estate interests the opportunity to take advantage of the qualified business income (QBI) deduction. The QBI write-off was created by the Tax Cuts and Jobs Act (TCJA) for pass-through entities. The...
Read MoreThe IRS and Treasury issued final regulations on October 4, 2019, that changed the rules on deficit restoration obligations. In short, the regulations address when a partner can, or cannot, disregard the obligation to restore their deficit balance in a capital account. In particular, the...
Read MoreAfter IRS Commissioner Charles Rettig’s comments on May 30, 2019, practitioners and investors waited anxiously for additional guidance clarifying the tax treatment of cryptocurrency. On October 9, 2019, the IRS released the much anticipated guidance in Revenue Ruling 2019-24 and an outline...
Read MoreIn early August, the IRS began issuing Notice CP2000 to advise taxpayers owning virtual currency that the income or payment information the IRS received from independent third-party sources does not match the virtual currency income information reported on taxpayers’ federal income tax...
Read MoreAs always, there is a lot going on in the tax world that impacts businesses and their owners, this year in particular due to the Tax Cuts and Jobs Act. It was my privilege to again serve as editor of the AICPA’s Tax Adviser August Tax Clinic, a special section in the professional journal...
Read MoreInformation Release 2019-132, issued on July 26, 2019, advises virtual currency owners to expect a letter providing information on how to pay back taxes through filing amended returns. Virtual currency investors were identified through ongoing enforcement actions, including the summons on the...
Read MoreThe Tax Cuts and Jobs Act (TCJA) created a significant new tax deduction for qualified business income (QBI) for so-called “pass-through” entities for 2018 through 2025. But it also created uncertainty about whether owners of rental real estate were eligible for the deduction. Recent...
Read MoreIf you own or lease your vehicle for business purposes, the IRS allows you to write off some of the cost of the vehicle via depreciation or lease expense. For the 2019 tax year, the IRS has updated the inflation-adjusted “luxury automobile” limits on certain deductions taxpayers can...
Read MorePursuant to statements made by IRS Commissioner Charles Rettig on May 30, 2019, much-anticipated cryptocurrency tax guidance should be released “very soon.” Rettig suggested the guidance, which would come in the form of a revenue ruling and a revenue procedure, could be released...
Read MoreThe IRS recently announced the inflation-adjusted maximum fair market value (FMV) of an employer-provided vehicle under the vehicle cents-per-mile and fleet-average special valuation rules. Employers can use these rules to value an employee’s personal use of such a vehicle for income and...
Read MoreOn April 17, 2019, the Department of Treasury issued the second set of proposed regulations regarding the Qualified Opportunity (QO) Zone Program. This long-awaited guidance further clarifies how to comply with the program and how to make it over some of the hurdles associated with structuring...
Read MoreThe IRS and the U.S. Department of the Treasury released round two of proposed regulations surrounding the Qualified Opportunity (QO) Zone Program today. The 169-pages of regulations address many areas, including:How businesses headquartered in designated QO Zones may benefit,The timeline for QO...
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