On June 5, 2020, the Internal Revenue Service (“ IRS ”) issued proposed regulations on the excise tax on excess tax-exempt organization executive compensation under Section 4960 of the Internal Revenue Code (the “ Excise Tax ”).
The proposed regulations expand upon and modify guidance that the Treasury Department and the IRS published on December 31, 2018 in Notice 2019-09 (the “ Notice ”). They contain a number of helpful new provisions, including a series of exemptions from “covered employee” status in certain situations where employees of for-profit entities serve as officers of, or provide services to, affiliated tax-exempt organizations.
Many things are taking place:
IRS Releases Proposed Regulations on Executive Compensation for Tax-Exempt Organizations | Morgan
The Internal Revenue Service and US Department of the Treasury have released proposed regulations governing the excise tax imposed by Internal Revenue Code Section 4960 on certain executive compensation paid to employees of tax-exempt organizations.
While the proposed regulations provide some relief to nonprofit volunteers, they still may impose significant disincentives for businesses to contribute the time and treasure of highly compensated executives to nonprofit affiliates. The issue is particularly relevant for small businesses because it indirectly imposes a tax on the remuneration of privately held businesses that Congress has otherwise determined not to be subject to deduction limitations, such as under Section 162(m).
INSIGHT: New Zealand—New Tax Disclosures Under Revised Overseas Investment Regime
Simon Akozu and Conor Masila, of MinterEllisonRuddWatts, discuss the upcoming changes to New Zealand's overseas investment regime, and the implications for overseas investors who are considering investing there.
Overseas investors who want to acquire significant New Zealand business assets or sensitive land may be required to make specific upfront tax disclosures to New Zealand's Overseas Investment Office (OIO) and New Zealand's Inland Revenue Department (IRD) under upcoming changes to New Zealand's overseas investment regime.
INSIGHT: Impact of Proposed IRS Regulations Under Section 45Q for Carbon Capture Credit
The IRS recently released proposed regulations for the carbon capture credit. Crowell attorneys walk through the history of the credit and what taxpayers need to know to claim the credit and situations that will result in recapture of the credit.
On May 28, 2020, the IRS released long-awaited proposed regulations under tax code Section 45Q, which provides the credit for carbon capture utilization and storage (CCUS).
The proposed regulations address some key technical issues regarding how the credit will apply, including standards for the following: secure geological storage; recapture; how taxpayers investing in CCUS equipment can contract with others to ensure capture and disposal of qualified carbon dioxide and other carbon oxide (qualified CO); definition of "carbon capture equipment;" and elections to transfer the credit.
Quite a lot has been going on:
Tax implications applied to the foreign contractor carrying out EPC Contract in Vietnam - Lexology
In recent years, the number of construction investment projects has been performed under the form of Engineering – Procurement – Construction contract, referred to as the “ EPC Contract ” in a synchronous and complete manner.
1| Corporate income tax (“CIT”) in Vietnam and permanent establishment (“PE”)
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3| Foreign contractor withholding tax (“FCWT”) – a collection mechanism of CIT and VAT from foreign contractors
Payments for Certain Healthcare Arrangements are Tax Deductible - Lexology
The IRS recently issued proposed regulations that address the treatment of amounts paid by an individual for a “direct primary care arrangement” or a “health care sharing ministry” (collectively, the “ Arrangements ”) as being tax-deductible “medical care expenses” under Section 213 of the Internal Revenue Code (the “ Code ”).
The preamble to the proposed regulations further confirms that, because payments for Sharing Ministries would constitute “medical insurance” under Section 213, an individual’s participation in a Sharing Ministry would prohibit his eligibility to participate in a HSA during the same period.
IRS Proposes Regulations that Define Real Property for Purposes of Like-Kind Exchanges, Providing
On June 11, 2020, the Internal Revenue Service (the “IRS”) issued proposed regulations that define the term “real property” for purposes of Section 1031 of the Internal Revenue Code of 1986, as amended (the “Code”).
Prior to 2018, where various requirements were satisfied, Section 1031 made it possible for taxpayers to engage in tax-free “like-kind” exchanges of property held for productive use in a trade or business or for investment, and the types of property that could be exchanged included tangible personal property as well as real property.
Virtual Currency Positions and Wash Sales Rule
Tax law has special rules that disallow a deduction for a loss on the sale of certain assets where the taxpayer purchases the same or substantially similar assets a short time before or after the sale that triggered the loss. This rule, called the wash sales rule, applies to prevent taxpayers from reporting losses from selling "stock" or "securities" as defined in the tax laws.
Taxpayers cannot deduct otherwise allowable losses if the losses are from a sale or other disposition of stock or securities and the taxpayers acquire substantially identical stock or securities (by a purchase or in a taxable transaction) within a period beginning 30 days before and ending 30 days after the date of the disposition (the 61-day prohibited period; I.R.C. § 1091).
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