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 More