Final regs issued on partnership’s allocation of creditable foreign tax expenditures
TD 9871, Reg. § 1.704-1 IRS has issued final regs on the operation of the safe harbor rule in Reg. § 1.704-1(b)(4)(viii), …
Final regs discuss intent to operate as a 501(c)(4) org notification requirement
TD 9873; Reg §1.506-1 The IRS has finalized regs under Code Sec. 506, that discuss the requirement that social welfare organizations notify …
IRS advises on interaction of corporate charitable deductions and NOLs
Code Sec. 170(a) allows a deduction for charitable contributions paid within the tax year. Code Sec. 170(b)(2)(A) limits a corporation’s current charitable contribution …
Tax Advocate issues report on earned income tax credit and “map” of tax system
Background. TAS is an independent organization within IRS whose employees assist taxpayers who are experiencing economic harm, who are seeking help …
IRS and Security Summit partners issue identity theft and tax security checklist
In 2015, IRS convened a Security Summit with chief executive officers and leaders of private sector firms and federal and …
Prop reliance regs explain excise tax on net investment income of colleges and universities
Preamble to Prop Reg REG-106877-18; Prop Reg §53.4968-1 IRS has issued proposed reliance regs for determining the 1.4% excise tax on …
Lack of prearranged plan didn’t save like-kind treatment for related party transaction
The Malulani Group, Limited, and Subsidiary, (CA 9 6/12/2019) 123 AFTR 2d ¶2019-776 The Court of Appeals for the Ninth Circuit …
IRS designates two additional Puerto Rico tracts as qualified opportunity zones
Notice 2019-42, 2019-29 IRB In a Notice, IRS has designated two additional census tracts in Puerto Rico as qualified opportunity …
IRS finalizes certain foreign tax credit regs
T.D. 9866; Reg §1.78-1, Reg §1.861-12, Reg §1.965-7 IRS has finalized certain of the foreign tax credit (FTC) proposed regs that it issued …
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 …