Lack of detail in IRS CDP determination didn’t affect court’s decision
Hinerfeld, TC Memo 2019-47 The Tax Court has held that a case law rule—that a court in dealing with an administrative …
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Chairman Clayton: Companies Should Provide More Disclosure on Human Capital Management
SEC Chairman Jay Clayton wants public companies to step up and provide more extensive information about how they manage their …
Partnership was not a domestic partnership in outbound transfer of intangibles
Chief Counsel Advice 201917007 In a redacted Chief Counsel Advice (CCA), IRS has determined that it had the authority under Reg …
Court: lawsuit settlement payment was part corporate deduction, part employee expense
Ferguson, TC memo 2019-40 The Tax Court has held that, where a custom homebuilder conducted his business via several corporations and …
IRS releases draft forms to compute qualified business income deduction
Draft 2019 Form 8995 (Qualified Business Income Deduction Simplified Computation) Draft 2019 Form 8995-A (Qualified Business Income Deduction) IRS has …
Proposed regs would tax income otherwise allocable to nonresident alien owner of ESBT
Preamble to Prop Reg REG-117062-18; Prop Reg §1.641(c)-1, Prop Reg §1.1361-1 IRS has issued proposed regs that would ensure that the income …
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Regs will clarify effect of suspension of miscellaneous itemized deductions on trusts and estates
Notice 2018-61, 2018-31 IRB In a Notice, IRS has announced that it intends to issue regs that clarify the effect …
Prop regs on Sec. 965 deemed repatriation/transition tax—Statutory background
Preamble to Prop Reg REG-104226-18, 8/1/2018; Prop Reg § 1.962-1, Prop Reg § 1.962-2,Prop Reg § 1.965-1, Prop Reg § 1.965-2, Prop Reg § 1.965-3, Prop …
Proposed BEAT regs: affiliated groups & their business interest deduction
Preamble to Prop Reg REG-104259-18; Prop Reg § 1.59A-1, Prop Reg § 1.59A-2, Prop Reg § 1.59A-3, Prop Reg § 1.59A-4, Prop Reg § 1.59A-5, Prop …