The Internal Revenue Service released regulations to restrict a valuable tax break that hedge fund managers were able to claim after an error in 2017 Republican tax law.
The change, published Friday, bars money managers from using some types of business entities, including S corporations and passive foreign investment companies, to take advantage of an exemption to rules for taxing carried interest.
"The Treasury Department and the IRS have concluded that the grant of regulatory authority in section 1061 is sufficient for the government to issue regulations" exempting S corporations and PFICs, the rule states, referring to the relevant tax code section in the 2017 law.
This may worth something:
Proposed Regulations Provide Guidance on Unrelated Business Taxable Income (UBTI) Calculation |
On April 24, 2020, the U.S. Treasury Department and Internal Revenue Service issued proposed regulations with respect to Section 512(a)(6) of the Internal Revenue Code. These regulations are designed to provide guidance on how an exempt organization determines if it has more than one unrelated trade or business, and if so, how the exempt organization calculates UBTI.
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Before the enactment of the TCJA, exempt organizations could aggregate income and loss from multiple UBTI activities.
John Hancock Tax-Advantaged Dividend Income Fund Notice to Shareholders - Sources of Distribution
BOSTON , July 31, 2020 /PRNewswire/ - John Hancock Tax-Advantaged Dividend Income Fund (NYSE: HTD ) (the "Fund"), a closed-end fund managed by John Hancock Investment Management LLC and subadvised by both Manulife Investment Management (US) LLC, and Wells Capital Management Incorporated, announced today sources of its monthly distribution of $0.1380 per share paid to all shareholders of record as of July 13, 2020 , pursuant to the Fund's managed distribution plan.
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This notice provides shareholders of the John Hancock Tax-Advantaged Dividend Income Fund (NYSE: HTD ) with important information concerning the distribution declared on July 1, 2020 , and payable on July 31, 2020 . No action is required on your part.
Tax Strategy: Proposed regs on qualified transport fringe benefits | Accounting Today
The Tax Cuts and Jobs Act amended Code Sec. 274 to disallow a deduction for the expense of any qualified transportation fringe benefit as defined in Code Sec. 132(f) provided to an employee of the taxpayer, effective for amounts paid or incurred after Dec. 31, 2017.
Code Sec. 132 generally excludes from gross income of an employee the value of certain fringe benefits, up to a maximum monthly excludable amount, $270 for 2020. These fringe benefits include transportation in a commuter highway vehicle between the employee's residence and place of employment, any transit pass, qualified parking, and any qualified bicycle commuting reimbursement.
Quite a lot has been going on:
Holiday or Headache? Retailers Juggle Back-to-School Tax Rules
It's the holiday season —the back-to-school sales and use tax holiday season. Still, a lot of e-commerce businesses aren't celebrating.
Thousands of remote sellers swept into state tax collection schemes for the first time this year are expected to have a tough time keeping up with the complicated rules for exempting sales tax across the 16 tax holiday states. Online sellers operating in multiple jurisdictions will have to contend with different tax-free calendars, different lists of exempt and non-exempt items, and different caps on the volume of merchandise consumers can purchase tax free.
Net Operating Losses of Tax-Exempt Organizations with More Than One Unrelated Trade or Business |
Since the enactment of the unrelated business income tax in 1950, section 512(b)(6) [1] and its predecessor allowed organizations subject to the unrelated business income tax (UBIT) to use the net operating loss (NOL) deduction in section 172 derived from net losses from one unrelated trade or business to reduce their overall “unrelated business taxable income” (UBTI) - even if derived from other, different, unrelated trades or businesses, subject to certain limitations.
New rules, for taxable years beginning after December 31, 2017, require the “siloing” of profits and losses within each particular line of unrelated trade or business. Section 512(a)(6) now requires a tax-exempt organization with more than one unrelated trade or business to calculate UBTI separately, including any NOL deduction, with respect to each trade or business.
IRS PLR: REIT's Floating Docks Are Real Estate Assets, Income From Storage Facilities Are Rents
Floating docks on properties of a real estate investment trust (REIT) are real property for purposes of Treasury Regulations Section 1.856-10(b) and, therefore, are real estate assets for purposes of tax code Section 856(c)(4) and Section 856(c)(5) , and amounts received for racking structure space in dry dock storage facilities on the properties won't be considered as other than rents from real property ( Section 856(d) ), the IRS ruled.
EU May Hit 'Pause' on Tax Talks | Treasury & Risk
Preparing your treasury department for what lies ahead means knowing what tools are available, and what s best for your organization.
Happening on Twitter
The IRS released regulations to restrict the valuable carried interest tax break that hedge fund managers were able… https://t.co/c0x1cRWfhS business (from New York and the World) Fri Jul 31 17:28:05 +0000 2020
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