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 …
Tax Court denies deductions and costs of goods sold claimed by medical-marijuana dispensary
Patients Mutual Assistance Collective Corp., et al., (2018) 151 TC No. 11 The Tax Court has denied a California medical-marijuana dispensary’s …
Proposed business interest regs: C corporation rules
Preamble to Prop Reg REG-106089-18; Prop Reg §1.163(j)-4, Prop Reg §1.163(j)-5, Prop Reg §1.163(j)-11 IRS has issued proposed regs under Code Sec. 163(j), as …
Applicable Federal Rates for December
Rev Rul 2018-30, 2018-49 IRB The Applicable Federal Rates for December 2018 are reproduced below. Table 1 Applicable Federal Rates …
Both employer and its officer can be liable for fraudulent information return damages
Czerw v. Lafayette Storage & Moving Corp, (DC NY 11/09/2018) 122 AFTR 2d ¶ 2018-5416 A district court has ruled on …
Official inflation-adjusted tax rate schedule and other tax figures for 2019
Rev Proc 2018-57, 2018-49 IRB, IR 2018-222, 11/15/2018 IRS has issued official inflation-adjusted tax rate schedules and other key tax figures …
Income attributable to brownfield credits is qualifying income for REIT purposes
PLR 201845001 In a private ruling, IRS has concluded that the right to receive brownfield credits, to the extent it …
Company and its foreign sales corporation aren’t same taxpayer under interest netting rules
Ford Motor Company, (CA FC 11/9/2018) 122 AFTR 2d ¶ 2018-5414 The Court of Appeals for the Federal Circuit, affirming a …