The IRS says a new proposal curtailing the its ability to hire and share information with outside contractors during tax audits goes beyond requirements imposed under a 2019 reform law.
The Taxpayer First Act ( Pub. L. 116-25 ), signed into law last summer, bars the IRS from sharing any books, papers, records, or other data obtained by summons with contractors, except when the contractor needs that information for the sole purpose of providing "expert evaluation and assistance" to the agency. The law also says only IRS or Office of Chief Counsel employees can question a summoned witness under oath.
In case you are keeping track:
Regs Would Conform GILTI High-Tax Exceptions
On July 20, 2020, the US Department of the Treasury (Treasury) and the Internal Revenue Service (IRS) issued proposed regulations (REG-127732-19) (the 2020 Proposed Regulations) that would conform the historic Subpart F high-tax exception under section 954(b)(4) with the new global intangible low-taxed income (GILTI) high-tax exception.
Subpart F High-Tax Exception under Section 954(b)(4) and Treas. Reg. § 1.954-1(d)
Section 951(a)(1) generally requires a US shareholder of a CFC to include in gross income its pro rata share of the corporation's Subpart F income for a taxable year. However, a US shareholder may elect to exclude from its gross income any item of Subpart F income that is subject to a high foreign income tax rate.
Takeaways from IRS Proposed Regulations on Carried Interest
On July 31, 2020, the Internal Revenue Service (the "IRS") and the U.S. Department of the Treasury (the "Treasury") issued proposed regulations (the "Proposed Regulations") providing guidance on Section 1061 of the Code, as implemented by the law commonly referred to as the Tax Cuts and Jobs Act of 2017.
As background, Section 1061 applies to an applicable partnership interest (an "API") held by or transferred to a taxpayer in connection with the performance by that taxpayer (or a related person) of substantial services in an applicable trade or business (an "ATB").
When It Comes to Alimony, Tax Doesn't Have to Be Complicated
When it comes to taxes, the formality and complexity of the tax code can lead some taxpayers to believe that compliance is always complicated. But sometimes, simple can be enough.
The Manual notes, "Preferably, the amount of support provided to family members should be established by a written agreement between the parties, or be adjudicated in the civilian courts." The Manual also requires that marines comply with a court order, a written agreement, or the interim financial Support standards of paragraph 15004.
Quite a lot has been going on:
IRS Publishes Proposed Regulations Applicable to Three-Year Carried Interest Holding Period
On Friday, July 31, 2020, the Internal Revenue Service (IRS) issued proposed regulations under Section 1061 of the Internal Revenue Code. Enacted as part of the 2017 Tax Cuts and Jobs Act, Section 1061 imposes a new three-year capital gain holding period applicable to interests in certain investment partnerships for tax years beginning on or after January 1, 2018.
As detailed in our 2018 update summarizing the Section 1061 rules , Section 1061 provides that certain capital gains attributable to “applicable partnership interests” are taxed at short-term capital gains rates unless the underlying asset is held for more than three years.
Wells Fargo Utilities and High Income Fund Announces Sources of Distribution | Business Wire
This Notice provides information about the sources of the Fund's monthly distributions. You should not draw any conclusions about the Fund's investment performance from the amount of this distribution or from the terms of the Fund's Managed Distribution Plan.
The Fund estimates that it has distributed more than its income and net realized capital gains; 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. A return of capital distribution does not necessarily reflect the Fund's investment performance and should not be confused with "yield" or "income."
NW Natural Holdings Reports Second Quarter and Year-to-Date 2020 Results | Business Wire
" We remain vigilant during this pandemic regarding the safety of our 1,200 employees and the 2.5 million people, businesses, and communities we serve. I want to extend my gratitude to our health care professionals and our employees for their dedication as they provide essential services during these unprecedented times," said David H. Anderson, president and CEO of NW Natural Holdings.
For the second quarter of 2020, net income from continuing operations decreased $7.2 million to a net loss of $5.1 million (or $0.17 per share), compared to net income from continuing operations of $2.1 million (or $0.07 per share) for the same period in 2019.
U.S. Moves to Tighten Regulations for Chinese Stock Listings (2)
A high-powered group of U.S. regulators said stock exchanges should set new rules that could trigger the delisting of Chinese companies, following mounting concerns that investors are being exposed to frauds.
The President's Working Group on Financial Markets said Thursday that in order to trade on a U.S. exchange, companies must grant American regulators access to their audit work papers. The group hasn't determined how to enforce the guidelines, said a senior Treasury Department official who briefed reporters on the condition of anonymity. While the final penalty would be removal from U.S. exchanges, the Treasury and Securities and Exchange Commission...
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