The "10 principal documents" required by the IRS to document intercompany transactions may have had their use at one time. Barbara Mantegani of Mantegani Tax PLLC argues that time has passed, and that the Treasury Department should consider replacing the documents with the three levels of documentation included in OECD transfer pricing guidance.
As transfer pricing continues to be one of the most, if not the most, important tax issue facing multinational corporations, and as the need to document one's transactions has expanded to a need to, in effect, tell the company's transfer pricing story, it may be time for the U.S. Treasury Department to consider a change to its regulations.
This may worth something:
Tax-avoidance case, suits against IRS get Supreme Court review | Accounting Today
The U.S. Supreme Court agreed to review a ruling that critics say would give the Treasury Department and Internal Revenue Service a sweeping shield from challenges to their regulations.
The justices said Monday they will hear arguments over a reporting requirement used by the IRS to police what it says are tax-avoidance schemes involving tiny insurance companies. The requirement includes a $50,000 penalty for noncompliance.
At issue is whether taxpayers and their advisers can challenge the reporting requirement, and others like it, without paying the penalty or waiting for the IRS to start enforcement proceedings.
A divided Cincinnati-based federal appeals court said the compliance penalty made the reporting requirement a tax, and insulated it from a preemptive legal attack. Under a law known as the Anti-Injunction Act, taxes generally can be challenged only after they are paid or the IRS has begun enforcement.
Trump team plots tax cuts and regulatory suspensions to boost a coronavirus recovery - POLITICO
The president's team is looking to bolster the economy — and turn the page from concerns about testing shortfalls.
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President Donald Trump has always preferred to play cheerleader rather than the bearer of bad news.
Trump kicked off the week with a two-hour Fox News virtual town hall to hype the initial reopening of economies in more than a dozen states, even as his own public health experts and advisers expressed renewed concerns about the ongoing spread and lack of firm control over Covid-19.
Novogradac's Opportunity Zones Working Group Seeks Relief, Guidance in Face of COVID-19 Pandemic
In a recent letter, the Novogradac Opportunity Zones (OZ) Working Group submitted a request to the Department of the Treasury (Treasury) and the Internal Revenue Service (IRS) seeking relief from certain provisions concerning the opportunity zones incentive due to the COVID-19 pandemic.
The OZ Working Group asked Treasury to provide relief under authority of Internal Revenue Code (IRC) Section 7508A, which is triggered by a federally declared disaster. The request also asks Treasury and the IRS to explicitly approve penalty relief provided for under the statute and certain extensions provided for under the regulations. Finally, the OZ Working Group asked that Treasury and the IRS make certain temporary modifications and clarifications to other regulatory guidance.
Quite a lot has been going on:
Omega Reports First Quarter 2020 Results | Coronavirus | baytownsun.com
Omega Healthcare Investors, Inc. (NYSE:OHI) (the "Company" or "Omega") today announced its results for the quarter ended March 31, 2020. The Company reported net income of $92.3 million or $0.39 per common share.
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For the quarter ended March 31, 2020, the Company reported net income of $92.3 million, or $0.39 per common share, on revenues of $253.0 million. This compares to net income of $72.2 million, or $0.34 per common share, on revenues of $223.7 million, for the same period in 2019.
DoubleLine Opportunistic Credit Fund Declares May 2020 Distribution | News | wfmz.com
LOS ANGELES , May 1, 2020 /PRNewswire/ -- The DoubleLine Opportunistic Credit Fund (the "Fund"), which is traded on the New York Stock Exchange under the symbol DBL, this week declared a distribution of $0.110 per share for the month of May 2020 . The distribution is subject to the following ex-dividend, record and payment dates set by the Fund's Board of Trustees.
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This news release is not for tax reporting purposes. The release has been issued to announce the amount and timing of the distributions declared by the Board of Trustees. There is a possibility that distributions may include ordinary income, long-term capital gains or return of capital. The amount of distributable income and the tax characteristics of the distributions are determined at the end of the taxable year.
New Treasury Regulations Address Income Aggregation Rules for Tax-Exempt Organizations - Lexology
On April 24, the Department of the Treasury (Treasury) and the Internal Revenue Service (the Service) issued proposed regulations (REG-106864-18) addressing the manner in which tax-exempt organizations calculate their unrelated business taxable income (UBTI). The proposed regulations should reduce the administrative complexity associated with such calculations and allow tax-exempt organizations to aggregate certain income streams and corresponding deductions.
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Section 512(a)(6) was enacted into law through the 2017 Tax Cuts and Jobs Act (TCJA) and has the effect of creating separate tranches, or “silos,” of UBTI for purposes of calculating a tax-exempt organization’s tax liability. Prior to this change under the TCJA, UBTI was computed by reducing the gross income of all unrelated trades or businesses by the allowed deductions from all unrelated trades or businesses.
NextGen Healthcare, Inc.
NextGen Healthcare, Inc. (Nasdaq: NXGN), a leading provider of ambulatory-focused technology solutions, announced today a business update and preliminary unaudited fiscal 2020 fourth quarter and year end March 31, 2020 operating results.
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"We achieved solid results in the fourth quarter and for the full year as the Coronavirus pandemic had minimal impact until March," said Rusty Frantz, president and chief executive officer of NextGen Healthcare. "As COVID-19 transitioned from headline to reality, we focused on employee safety, business continuity and financial strength to ensure we can guide and help our provider customers during this tumultuous period and we remain focused on our end-to-end solutions strategy.
Happening on Twitter
The forward 12-month P/E ratio for $SPX is 19.1, which is above the 5-year average (16.7) and above the 10-year ave… https://t.co/z2IxzZvqa9 FactSet (from Worldwide) Sun Apr 26 19:01:02 +0000 2020
Mr. 10,000 aka @joethomas73 gives insight about his consecutive snap streak and what he was thinking when he was ap… https://t.co/zaEoayaDJs NFLFilms (from New Jersey) Tue Apr 28 15:02:28 +0000 2020
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