As part of the general move to better-for-you beverages, non-alcoholic (NA) options have been and will likely continue to be on the rise. However, how NA is treated, or not treated, as "beer" has significant impact on its potential route to market. The below summarizes the overall treatment of NA beer under US federal law, as well as examples of restrictions on direct-to-consumer (DTC) shipments imposed by certain states.
Tax Treatment: The Alcohol and Tobacco Tax and Trade Bureau's (TTB) regulations define "beer" as a fermented beverage containing 0.5% or more alcohol by volume (ABV) and brewed or produced from malt, wholly or in part, or from any substitute for malt. ( See : 27 C.F.R. § 25.11.) The regulations refer to a malt beverage containing less than 0.5% ABV as a "cereal beverage." ( See: 25.11.
Other things to check out:
IRS Proposes Regulations for Excess Executive Pay
By way of background, Section 4960 imposes an excise tax equal to the corporate tax rate (21 percent for 2020) on that portion of a covered employee's pay that exceeds $1 million or is treated as an excess parachute payment. The tax applies to an applicable tax-exempt organization (called an "ATEO") or a related organization paying excess remuneration to a covered employee. The tax also applies to an ATEO's payment of an excess parachute payment.
Generally, under the proposed regulations, an employee is treated as a covered employee if he or she is one of an ATEO's five highest-compensated employees, including pay from related organizations. Once an employee meets the definition of a covered employee, the employee is always a covered employee (even if the employee ceases to be one of the top five highest compensated employees or terminates employment).
IRS Offers Settlements to Tax-Advantaged Land Deal Investors (3)
Years after identifying a pattern of potentially abusive land conservation deals , the IRS has offered to settle a number of pending cases with a warning that it is the best deal participants will get.
Tax code Section 170(h) allows for substantial tax deductions if land owners donate the right to develop their property in order to conserve it.
The offer targets syndicated conservation easements in particular, where promoters come together to encourage investors to purchase ownership interests in property through partnerships, using promotional materials that may suggest that prospective investors can get a share of the tax deduction worth significantly more than their investment amount. The IRS has flagged those types of deals on its most recent "Dirty Dozen" list of alleged tax scams.
United States: An Ounce of Prevention - Plans to Protect Loss Deduction in COVID-19 Environment
Baker McKenzie attorneys discuss the increased risks under the section 382 loss limitation rules in the COVID-19 environment. This article was previously published in Bloomberg Tax’s Daily Tax Report.
In the current Covid environment, many companies are facing unprecedented net operating losses. The CARES Act generally allows companies to carry back losses incurred in 2018, 2019, and 2020 for five years in an effort to provide liquidity. Unfortunately, many companies will not be able to absorb these losses within this time frame, particularly if the company had NOLs in the years to which the five-year period relate.
Not to change the topic here:
Proposed Regulations Regarding TCJA Disallowance for Employee Commuting and Parking Costs a Mixed
TCJA added new Section 274(a)(4) to the Internal Revenue Code to disallow the employer’s deductions for the cost of providing QTFs to employees, as defined in Section 132(f). QTFs are excluded from an employee’s gross income up to an inflation-adjusted monthly limit ($270 in 2020).
Compensation Reduction Arrangements . The proposed regulations reaffirm the IRS’s position that QTFs provided through a compensation reduction agreement are subject to the deduction disallowance of section 274(a)(4). Some commentators had suggested that there should not be a deduction disallowance for an otherwise deductible expense as a result of the employee’s election to use some compensation to purchase qualified parking on a pre-tax basis.
Statement Pursuant to Section 19(a) of the Investment Company Act of 1940: DDF | Business Wire
The following table sets forth the estimated amount of the sources of distribution for purposes of Section 19 of the Investment Company Act of 1940, as amended, and the related rules adopted thereunder. The Fund estimates the following percentages, of the total distribution amount per share, attributable to (i) net investment income, (ii) net realized short-term capital gain, (iii) net realized long-term capital gain and (iv) return of capital or other capital source.
* * *
Subject to the foregoing, the Fund estimates (as of the date hereof) that it has distributed more than its income and net realized capital gains for the fiscal year ending November 30, 2020; therefore, a portion of your distribution may be a return of capital. A return of capital may occur for example, when some or all of the money that you invested in the Fund is paid back to you.
Editorial: US retaliation for taxes on tech giants could deepen economic crisis - The Mainichi
The United States is considering invoking punitive tariffs in retaliation for moves by the European Union and nine countries including India and Brazil to introduce digital service taxes on big tech companies.
Countries in Europe and other parts of the world are financially struggling to cope with the novel coronavirus pandemic as they mete out large-scale economic packages. They are thus aspiring to tap the financial resources of information technology giants that are thriving from the rapid spread of online meetings and internet shopping amid measures to prevent viral transmissions. The United States, home to major tech firms such as Google and Amazon, is lashing back at those moves.
Treasury and IRS Proposed Section 4960 Excise Tax Regs.
The US Department of the Treasury has released long-expected proposed regulations regarding the section 4960 excise tax on certain remuneration or separation amounts paid to the five highest paid employees of a tax-exempt organization. The new proposed regulations continue the tough approach previously taken on section 4960 issues, while also providing some new exceptions and important clarifications.
Summary : The US Department of the Treasury released long-expected proposed regulations regarding the section 4960 excise tax ( i.e. , the 21% excise tax on vested remuneration over one million dollars paid to a covered employee, and on excess parachute payments triggered by an involuntary separation from service). Prior to these proposed regulations, the Internal Revenue Service (IRS) had issued a lengthy notice (Notice 2019-09, Dec.
No comments:
Post a Comment