This week we look at preserving net operating loss deductions; taxable presence in another country; California's murky alternative apportionment; flexibility and tax consequences for the PPP; midyear changes to cafeteria plans; Puerto Rico investment incentives; interactions of economic relief measures; transfer pricing in the coronavirus pandemic age; tax technology in pandemic recovery; U.K. financial services and the euro-zone crisis; and hidden VAT costs in philanthropy. We'll hear from:
Not to change the topic here:
Proposed Regulations on UBTI Provide Guidance to Tax-Exempt Organizations Making Fund Investments
On April 23, 2020, the Treasury Department and the Internal Revenue Service (the “IRS”) issued proposed regulations (the “Proposed Regulations”) under Section 512(a)(6) of the Internal Revenue Code (the “Code”).
In August 2018, the Treasury Department and the IRS issued Notice 2018-67 (the “Notice”), which provided interim guidance on the application of Section 512(a)(6). We previously discussed the Notice in an earlier post . We recently discussed the Proposed Regulations in a post on our Tax Talks blog; however this post is intended to be geared toward our clients in the private funds industry.
IRS Section 45Q Carbon Capture Projects Regulations
The proposed carbon capture regulations provide detailed rules and clarity on the following issues:
Standards for contracting with third parties to dispose of, inject or utilize the captured carbon oxide
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Flexible rules for transferring all or a portion of the Section 45Q credit to the party or parties disposing of the captured carbon oxide
On May 28, 2020, the U.S. Department of the Treasury issued long-awaited proposed regulations under Section 45Q of the Internal Revenue Code of 1986, as amended, providing guidance on how taxpayers may qualify for tax credits with respect to carbon capture projects. In general, the proposed regulations provide much needed clarity regarding carbon oxide capture, use and sequestration and will encourage new investment in carbon capture projects.
U.S. Treasury Proposes New Guidance for Tax Deductions - Lexology
The U.S. Department of the Treasury (Treasury) recently proposed two separate rulemakings implementing updates to the Internal Revenue Code related to 1) the deduction of fines and penalties and 2) tax credits for carbon capture and sequestration.
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"As Company Secretary, I find these articles very useful and appropriate and also share them with the lawyers and paralegals in the department".
In case you are keeping track:
Treasury, IRS issue final regulations providing relief for certain tax-exempt organizations |
The Department of the Treasury and the Internal Revenue Service today issued final regulations clarifying the reporting requirements generally applicable to tax-exempt organizations.
The final regulations reflect statutory amendments and certain grants of reporting relief announced by the Treasury Department and the IRS in prior guidance to help many tax-exempt organizations generally find the reporting requirements in one place.
Among other provisions, the final regulations incorporate the existing exception from having to file an annual return for certain organizations that normally have gross receipts of $50,000 or less. That exception was previously announced in Revenue Procedure 2011-15. The regulations also provide that the requirement to report contributor names and addresses on annual returns generally applies only to returns filed by Section 501(c)(3) organizations and Section 527 political
Proposed Treasury Regulations Clarify Requirements for Deducting Restitution and Legal Compliance
On May 13, 2020, the Treasury Department and the Internal Revenue Service proposed revisions to the regulations under section 162(f) of the Internal Revenue Code (the “Proposed Regulations”). [1] Generally, section 162(f) governs the deductibility of amounts paid or incurred by a taxpayer to, or at the direction of, a government entity for a violation (or alleged violation) of law.
Before the enactment of the TCJA, section 162(f) generally disallowed deductions in computing taxable income for any “fine or similar penalty paid to a government for the violation of a law.” Many disputes arose between taxpayers and the IRS with respect to what constituted a fine or similar penalty [2] and what kind of proof a taxpayer was required to offer to show that an amount did not come within the disallowance provision. [3]
IRS Provides Answers About Coronavirus Related Tax Relief for Qualified Opportunity Funds and
Taxpayers who sold property for an eligible gain and who would have had 180 days to invest in a QOF to defer that gain, may have additional time. Notice 2020-39 provides that if a taxpayer’s 180th day to invest in a QOF would have fallen on or after April 1, 2020, and before December 31, 2020, the taxpayer now has until December 31, 2020 to invest that gain into a QOF. (The 180th day for some of these taxpayers was already postponed through July 15, 2020, under Notice 2020-23.
The guidance also provides that, due to the COVID-19 pandemic, a QOF’s failure to hold less than the 90% of its assets in Qualified Opportunity Zone Property on any semi-annual testing dates from April 1, 2020, through Dec. 31, 2020, is due to reasonable cause under section 1400Z-2(f)(3) and such failure does not prevent qualification of an entity as a QOF or an investment in a QOF from being a qualifying investment.
Albemarle puts the brakes on changes to homestay regulations | Local News | dailyprogress.com
The Board of Supervisors last week voted to change the regulations, which now divide the county into three categories by zoning districts and size.
Buy Local is a directory of businesses in our area who are offering gift cards for sale. If you do not currently have a gift card program, but would like to offer one right now or on an on-goi…
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Come eat with us and experience, "...your gateway to Naples, Italy!" We're open from 11:00am…
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