The final rules also contain amendments to regulations issued under Secs. 962 (election by individuals to be taxed at corporate tax rates), 1502 (how the deduction applies to consolidated groups), 6038 (information reporting for certain controlled foreign corporations (CFCs) and partnerships), and 6038A (information reporting for certain foreign-owned corporations).
Sec. 250 was added to the Code by the law known as the Tax Cuts and Jobs Act, P.L. 115-97, and is effective for tax years beginning after Dec. 31, 2017. Sec. 250 is designed counteract the effect of providing a lower U.S. effective tax rate for the active earnings of a CFC of a domestic corporation through the GILTI deduction by providing a lower effective U.S. tax rate for FDII earned directly by the domestic corporation through a 37.5% deduction. The Sec.
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Supreme Court rules Trump will have to fight to keep secret his taxes, financial records
WASHINGTON — The U.S. Supreme Court on Thursday gave President Donald Trump a chance to beat back House Democrats' efforts to obtain his financial records but ruled he is not immune from the Manhattan district attorney's attempt to get his taxes .
Manhattan District Attorney Cyrus Vance Jr. wants years worth of Trump's tax returns as part of his probe into hush-money payments to two women while House Democrats sought financial records from the Trump Organization's accounting firm and two banks to determine if foreign governments, including Russia, hold sway over him.
Does an Excise Tax Apply When Company Employees Serve as Directors and Officers of the Company
New proposed IRS regulations clarify that the tax will not apply in most cases when company officers/employees serve as directors and officers of the company foundation for no compensation from the foundation
This article originally appeared on the Wisconsin Philanthropy Network blog, and is republished here with permission.
In a prior blog post (July 2019), we addressed the potential for the new section 4960 excise tax (which was adopted as part of the 2017 tax reform bill) to apply when highly compensated company employees also served as directors and officers of the company foundation. At that time, we argued that the tax should not apply based on available guidance, although there was some uncertainty because the IRS had not directly addressed it.
Supreme Court decisions likely Thursday in fight over Trump tax returns, financial records
WASHINGTON — The Supreme Court said it will announce the last of the decisions from its current term on Thursday, which almost certainly means the court will reveal its rulings on whether Congress and a New York state prosecutor can get access to President Donald Trump's business records, including his tax returns.
The Trump rulings will be announced beginning at 10 a.m. ET, unless the court is unable to reach a decision and wants them held over to be reargued next term, which seems unlikely.
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Proposed Treasury Regulations Define 'Real Property' for Section 1031 Like-Kind Exchanges and
On June 11, the IRS released Proposed Treasury Regulations (the Proposed Regulations) under Section 1031 of the Internal Revenue Code, as amended (the Code), which provide a much-awaited definition of “real property” and offer a safe harbor for taxpayers engaged in deferred like-kind exchanges who receive “incidental” personal property as part of their replacement property acquisition.
Under a Section 1031 exchange (also called a like-kind exchange), no taxable gain or loss shall be recognized on the exchange of property held for productive use in a trade or business or for investment if such property is exchanged solely for property of like kind which is to be held either for productive use in a trade or business or for investment. A Section 1031 exchange can be structured as either a “simultaneous” exchange or a “deferred” exchange.
IRS Land Deal Offer Has Little to Entice Challengers to Settle
The IRS may find few takers for its offer to settle litigation over potentially abusive land deals, even though the agency warned investors they won't be offered better terms.
While the IRS positioned its offer as a good one following a string of agency victories in the U.S. Tax Court, people familiar with the transactions say the offer won't be attractive to many. They cited three limiting factors: The deal only applies to enforcement actions that have already made their way to the courts, all partners in an easement deal are required to accept the settlement for it to be valid, and the offer includes no benefit for the deal promoters.
Temporary Regulations Provide NOL Carryback Waiver Relief to Consolidated Groups | Shearman &
As discussed below in more detail, the Temporary Regulations provide welcome relief to consolidated groups that acquired a member within the past five years and ensure that such consolidated groups do not need to balance (i) losing the portion of a post-acquisition CNOL attributable to an acquired member against (ii) relinquishing the carryback for the entire CNOL generated by the consolidated group by making the general waiver election set forth in section 1.1502-21(b)(3)(i) of the Treasury
Colorado aims to combat vaping with laws, lawsuits and taxes | FOX21 News Colorado
COLORADO SPRINGS — One day after Colorado Attorney General Phil Wieser announced a lawsuit against vaping manufacturing giant Juul, Governor Jared Polis signed a bill that will ask voters to raise taxes on tobacco products and create a tax on nicotine products.
“A tax on tobacco has proven to be one of the most effective means of decreasing rates of smoking,” said Dr. Ted Maynard, a retired pediatrician who is now the president of the Colorado chapter of the American Academy of Pediatrics.
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