OMB Begins Review of Proposed and Final Regulations Under Section 163(j)
Posted on Jun 17, 2020 in Uncategorized
On June 15, Treasury submitted final and proposed regulations to the Office of Management and Budget (OMB) for review. The IRS had indicated that the modifications to the regulations since OMB’s last review of the package reflect changes made to section 163(j) under the Coronavirus Aid, Relief, and Economic Security (CARES) Act. Among other provisions, the CARES Act amended section...
IRS Releases Proposed Regulations on Like-Kind Exchanges
Posted on Jun 11, 2020 in Uncategorized
Today, the IRS released proposed regulations under section 1031, which provides nonrecognition treatment for certain like-kind exchanges of property. The Tax Cuts and Jobs Act (TCJA) limited the application of the provision to exchanges of real property. The proposed regulations would update the existing regulations under section 1031 to take into account the changes made to the...
IRS Issues Guidance on CARES Act changes to Section 163(j)
Posted on Apr 15, 2020 in Uncategorized
The IRS has issued Rev. Proc. 2020-22 to provide guidance to taxpayers applying the provisions of section 163(j), as amended by the CARES Act. Among other provisions, the CARES Act amended section 163(j) to allow taxpayers to deduct up to 50% of their adjusted taxable income (up from 30%), plus interest income and floor plan financing income, for taxable years beginning in either 2019...
OMB Completes its Review of Proposed Regulations under Section 163(j)
Posted on Mar 24, 2020 in Uncategorized
The Office of Management and Budget (OMB) has completed its review of proposed regulations under section 163(j). Section 163(j) generally limits a taxpayer’s interest deduction to the sum of its business interest income, floor plan financing interest, and 30% of its adjusted taxable income. The IRS had previously stated that the proposed section 163(j) regulations would likely be...
OIRA Completes Its Review of Final 163(j) Regulations
Posted on Feb 5, 2020 in Uncategorized
On January 31, the Office of Management and Budget (OMB) completed its review of final regulations under section 163(j). Section 163(j) generally limits a taxpayer’s interest deduction to the sum of its business interest income, floor plan financing interest, and 30% of its adjusted taxable income. The IRS had previously stated that the final regulations would likely be released along...
Treasury and IRS Issue Final Regulations on Investing in Qualified Opportunity Funds
Posted on Dec 20, 2019 in Uncategorized
On December 19, Treasury and the IRS released final regulations regarding investments in opportunity zones under section 1400Z-2. Opportunity zones were created by the Tax Cuts and Jobs Act and allow tax benefits for investments in low-income communities, through what are termed qualified opportunity funds (“QOF”). The final regulations provide guidance on the ability of taxpayers to...
OMB Begins Review of Final Section 163(j) Regulations
Posted on Dec 19, 2019 in Uncategorized
The Office of Management and Budget (OMB) received final regulations under section 163(j) on December 17. Section 163(j) generally limits a taxpayer’s interest deduction to the sum of its business interest income, floor plan financing interest, and 30% of its adjusted taxable income. While the OMB website does not state whether the regulations are subject to expedited review, IRS...
IRS LB&I Division Announces Section 965 Compliance Campaign
Posted on Nov 5, 2019 in International Tax
On November 4, the IRS Large Business and International Division (LB&I) announced a new compliance campaign directed at promoting compliance with section 965. Section 965, enacted by the Tax Cuts and Jobs Act, generally imposes a transition tax on a US shareholder’s pro rata share of the accumulated earnings and profits of certain foreign corporations. The LB&I campaign will...
IRS Releases Final Regulations under Section 168(k)
Posted on Sep 13, 2019 in Tax Accounting
Today, Treasury and the IRS released final regulations under section 168(k). Amended by the Tax Cuts and Jobs Act, section 168(k) generally allows full expensing of certain depreciable property. The final regulations address the requirements to qualify for the additional depreciation deduction and elections related to the deduction. Read the final regulations: TD 9874 Read the proposed...
IRS Allows Election Relief for Bonus Depreciation
Posted on Aug 1, 2019 in Uncategorized
On July 31, 2019, the IRS issued Rev. Proc. 2019-33, which allows taxpayers to change their elections regarding bonus depreciation for property acquired after September 27, 2017 and placed in service during the taxpayer’s 2016 or 2017 taxable year. Under the revenue procedure, a taxpayer may make late elections to use bonus depreciation on such property or revoke its election to use...
OIRA Receives Proposed and Final Regulations under Section 168(k)
Posted on Jul 29, 2019 in Uncategorized
On July 25, 2019, the Department of Treasury and the Internal Revenue Service submitted final and proposed regulations under section 168(k) to OIRA (the Office of Information and Regulatory Affairs), which is part of the OMB (Office of Management and Budget). Amended by the Tax Cuts and Jobs Act, section 168(k) generally allows full expensing of certain depreciable property. The...
Passthrough Regulations and Guidance Released
Posted on Jan 24, 2019 in News, Tax Accounting
Final section 199A regulations and additional proposed rules concerning passthrough deductions were released on January 18. The final regulations concern the 20 percent business income deduction available to passthrough owners meeting certain income thresholds that was introduced under the Tax Cuts and Jobs Act (TCJA). Included in the final regulations are a technical definition of...
House Republicans Release Tax Package
Posted on Nov 28, 2018 in News, Tax Accounting
House Republicans released a 297 page tax bill on the evening of November 26, with the possibility of voting on the proposed bill as soon as this week. The legislation includes a number of “extenders,” which would renew certain tax provisions set to expire; tax breaks for smaller businesses; and technical corrections to the Tax Cuts and Jobs Act (TCJA) passed in 2017. The five...
IRS Releases Business Interest Expense Proposed Regulations
Posted on Nov 27, 2018 in News, Tax Accounting
The IRS has released proposed regulations (REG-106089-18) concerning the business interest expense deduction limits applied to certain taxpayers. As amended by the Tax Cuts and Jobs Act (TCJA), section 163(j) generally places a limit on the amount of deductible business interest expenses in a current taxable year. The proposed regulations, released on November 26, provide rules for...
OIRA Receives Section 267A Regulations for Review
Posted on Nov 16, 2018 in International Tax
The IRS on November 13th submitted its proposed section 267A anti-hybrid regulations to the Office of Information and Regulatory Affairs for expedited review. Section 267A of the Tax Cuts and Jobs Act, eliminates deductions for any “disqualified related party amount” paid or accrued through a related hybrid entity or transaction. The regulations are expected to address such issues as...