Friday, October 30, 2020

Tax regulations to consider in borrowing from or lending by friends or relatives

Publisher: mint
Date: 2020-10-30T12:07:32 05:30
Author: Renu Yadav
Twitter: @mint
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And here's another article:

Implementing a Framework for Border Tax Adjustments in US Greenhouse Gas Tax Legislation and

Many proposals for greenhouse gas (GHG) tax legislation in the United States call for border tax adjustments (BTAs)—export rebates and import charges—to defend against GHG leakage and unfair competition in international trade caused by less stringent GHG policies in other nations. For similar reasons, the European Union also is seeking to establish a border tax on imports as it strengthens its GHG policies.

Without such border adjustments, key domestic constituencies in the United States and elsewhere—including labor, business, and communities where affected industries play a major role in regional economies—would oppose the GHG tax. However, trading partners, especially those major developing nations that would be disadvantaged by such a tax, could pose serious challenges, especially if BTAs violate World Trade Organization (WTO) obligations.

Publisher: Resources for the Future
Author: RFF Visiting Fellow Brian Flannery summarizes two of his recent coauthored reports that outline how policymakers should approach the development of border tax adjustments which also comply with US obligations under the World Trade Organization as part of greenhouse gas tax legislation
Twitter: @ResourcesMag
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Biden's tax plan looks to rob future generations of farmers | TheFencePost.com

The outcome of the upcoming presidential election stands to drastically impact Americans' checkbooks. Both the individual income tax rate and the ability to transfer wealth between generations could be greatly affected if former vice president Joe Biden is elected.

The "American dream" of financial mobility and generational wealth transfer could be at risk under Biden's tax plan. With Biden planning to hit Americans with some of the most extreme raises in estate taxes and capital gains in history, it may be advisable to consider revisiting your estate plan with your accountant and attorney to protect your assets from the drastic increase in taxes.

Author: Katherine E Mercki
Twitter: @FencePostNews
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Trump's ultra-low tax bills are what happens when government tries to make policy through the tax

Gary Winslett does not work for, consult, own shares in or receive funding from any company or organization that would benefit from this article, and has disclosed no relevant affiliations beyond their academic appointment.

* * *

People tend to have one of two reactions to the revelation that President Donald Trump has paid little to no taxes in recent years: He's either an amoral tax cheat or he's smart .

Publisher: The Conversation
Author: Gary Winslett
Twitter: @ConversationUS
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Not to change the topic here:

IRS Issues Section 1446(f) Final Regulations | K&L Gates LLP - JDSupra

On 7 October 2020, the Treasury Department and the Internal Revenue Service (IRS) released final regulations under Code Section 1446(f) 1 (the Final Regulations), which clarify aspects of the withholding requirements with respect to the disposition of partnership interests by non-U.S. persons. 2

The 2017 Tax Cuts and Jobs Act 3 added Section 864(c)(8), which provides that gain or loss from the sale, exchange, or other disposition of a partnership interest by a non-U.S. person is effectively connected with the conduct of a trade of business in the United States to the extent that the person would have had effectively connected gain or loss had the partnership sold all of its assets at fair market value.

Publisher: JD Supra
Twitter: @jdsupra
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IRS Releases Final Withholding Tax Regulations on Sales of Partnership Interests - Lexology

Section 1446(f) generally requires a transferee of a partnership interest to deduct and withhold a tax equal to 10% of the amount realized on the disposition of such interest if any portion of the gain would be treated as effectively connected with the conduct of a trade or business within the United States (“ECI”). Effectively, withholding under Section 1446(f) is an enforcement mechanism for liability imposed under Section 864(c)(8).

Given the complexities of applying the withholding rules to PTP interests, the IRS released Notice 2018-18, which temporarily suspended the requirement to withhold on amounts realized in connection with the sale, exchange or disposition of PTP interests. The IRS also released Notice 2018-29 which provided temporary guidance and announced an intent to issue proposed regulations with respect to the sale, exchange or disposition of non-PTP interests and, subsequently, the Proposed Regulations.

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Why Tax Was—And Will Remain—at the Epicenter of a Covid-19 Recovery
Twitter: @tax
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Treasury Releases Foreign Tax Credit Regulations

On September 29, 2020, the US Department of the Treasury (Treasury) and the Internal Revenue Service (IRS) issued final foreign tax credit regulations (the "2020 Final Regulations") that include the allocation and apportionment of: (1) stewardship expenses; and (2) research and experimentation (R&E) expenses. The 2020 Final Regulations come after the Treasury and IRS issued proposed regulations (the "2019 Proposed Regulations") on December 17, 2019.

In response to comments, the Treasury and IRS made two important changes in the 2020 Final Regulations regarding stewardship expenses. First, the 2020 Final Regulations turn off the affiliated group rules for stewardship expenses. Thus, a taxpayer treats its US affiliates as separate entities in allocating and apportioning its stewardship expenses.

Publisher: The National Law Review
Date: 5493B547C0AB527FF4CF8C4D0127302A
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