What’s new for 2019: a roundup of tax changes going into effect this year—Part II
A number of important tax changes go into effect in 2019. Some were ushered in by legislation such as the …
IRS issues interim guidance on excess remuneration paid by exempt orgs
Notice 2019-9 In a Notice, IRS has provided interim guidance on Code Sec. 4960, added by the Tax Cuts and Jobs …
IRS finalizes regs on public approval requirement for private activity bonds
T.D. 9845, 12/28/2018; Reg. §1.147(f)-1 TD 9845, Public Approval of Tax-Exempt Private Activity Bonds IRS has issued final regs on the …
Final partnership audit regs: Administrative Adjustment Requests (AARs)
TD 9844, 12/21/2018; Reg § 301.6221(a)-1; Reg § 301.6222-1; Reg § 301.6225-1; Reg § 301.6225-2; Reg § 301.6225-3; Reg § 301.6226-1; Reg § 301.6226-2; Reg § 301.6226-3; Reg § …
Final centralized partnership audit regs: consistency requirement
TD 9844, 12/21/2018; Reg § 301.6221(a)-1; Reg § 301.6222-1; Reg § 301.6225-1; Reg § 301.6225-2; Reg § 301.6225-3; Reg § 301.6226-1; Reg § 301.6226-2; Reg § 301.6226-3; Reg § …
Final centralized partnership audit regime regs: scope
TD 9844, 12/21/2018; Reg § 301.6221(a)-1; Reg § 301.6222-1; Reg § 301.6225-1; Reg § 301.6225-2; Reg § 301.6225-3; Reg § 301.6226-1; Reg § 301.6226-2; Reg § 301.6226-3; Reg § …
Prop regs explain determination of foreign partner’s gain or loss from sale or exchange of partnership interest
Preamble to Prop Reg REG-113604-18; Prop Reg § 1.864(c)(8)-1, Prop Reg § 1.897-7 Proposed Regs: Gain or Loss of Foreign Persons from Sale or Exchange …
Automatic consent procedures for insurance company changing basis of computing reserves under TCJA
Rev Proc 2019-10, 2019-2 IRB In a Revenue Procedure, IRS has provided the procedures under Code Sec. 446 and Reg § 1.446-1(e) for an …
Moves that will maximize the new deduction for pass-through income
For tax years that begin after Dec. 31, 2017 and before Jan. 1, 2026, noncorporate taxpayers that meet certain requirements …
Supreme Court won’t review 50% owner’s liability for trust fund penalty
U.S. v. Commander, (CA 3 5/25/2018) 121 AFTR 2d 2018-1861, cert denied 12/3/2018 The Supreme Court has declined to review a …