In case you are keeping track:
United States: IRS proposes regulations further limiting Attorney outside Contractor
The Internal Revenue Service (IRS) has issued new proposed regulations that would further limit the IRS’s ability to use private attorneys as contractors. The newly proposed regulations, published on 7 August 2020 (“ 2020 Proposed Regulations “), replace proposed regulations issued in 2018.
On 14 July 2016, the IRS published final regulations (T.D. 9778) under Code Section 7602 (“ 2016 Final Regulations “). The 2016 Final Regulations permitted, among others, nongovernmental attorneys who serve as contractors to participate fully in the interview of a person who the IRS has summoned as a witness to provide testimony under oath.
GILTI High-Tax Exclusion: An Additional Planning Tool for Noncorporate US Shareholders |
An individual or trust US shareholder of a controlled foreign corporation (CFC) faces harsh treatment under the global intangible low-taxed income (GILTI) regime. These tax implications have forced these taxpayers to pursue planning to mitigate their US tax liability.
The GILTI regime requires a US shareholder of a CFC to include a significant amount of the CFC’s income in its gross income on an annual basis. In so doing, a domestic C corporation shareholder can reduce its US tax liability associated with GILTI by claiming a deduction equal to 50% of its GILTI amount, and by also claiming a foreign tax credit equal to 80% of foreign taxes paid or accrued.
FAQs on IRS Final Regulations for Five-Year HTC | Novogradac
The regulations include a general rule for calculating the HTC, definitions for the terms "ratable share" and "rehabilitation credit determined," and rules to coordinate changes to Internal Revenue Code (IRC) Section 47 with special rules in IRC Section 50 relating to dispositions, basis adjustment and income inclusion. The rules became effective Sept. 18, 2020. The following are common questions about the impetus behind the final regulations as they relate to various parties to HTC deals.
In case you are keeping track:
The government is adjusting certain tax measures applicable to individuals and businesses
QUÉBEC CITY, Nov. 6, 2020 /CNW/ - The Ministère des Finances is publishing today an information bulletin that announces changes to the Québec taxation system mainly related to the impact of the current crisis and the implementation of federal government measures.
Canada Recovery Benefits
Québec tax legislation will be amended to allow the deduction of repayments by taxpayers regarding overpayments of Canada Recovery Benefits.
Assistance that affects tax incentives
The tax legislation will be amended with respect to the excluded amounts of assistance for the application of certain tax credits in the cultural sector and to the definition of the expression "non-government assistance" for the purposes of tax incentives.
New set of Sec. 199A final regulations
On June 24, 2020, the IRS issued additional final regulations (T.D. 9899) concerning the qualified business income (QBI) deduction under Sec. 199A. These final regulations clarify what is considered QBI and how to calculate it in certain situations. More particularly, the new rules provide guidance on:
Sec. 199A provides individual taxpayers (and some trusts and estates) a deduction of up to 20% of QBI from a U.S. trade or business operated as a sole proprietorship or through a partnership, S corporation, trust, or estate. Taxpayers can also take a deduction of up to 20% of their combined qualified real estate investment trust (REIT) dividends and qualified publicly traded partnership (PTP) income (Secs. 199A(a) and (b)(1)(B)).
Canada | Freeman Law - JDSupra
Quick Summary . In 1867, the United Kingdom passed a Parliamentary act establishing what is now known as Canada. Today, Canada, the largest country in the Western Hemisphere, is a federation of ten provinces and three territories.
Following its formation in 1867, Canada’s new government was provided with the power to raise money by taxation. Moreover, the new government was divided between the federal government and the provincial governments. Generally, the federal government was tasked with providing railways, roads, bridges, and harbors. Conversely, the provincial governments were responsible for providing its citizens with education, health, and welfare.
FedEx wants $89 million tax refund in lawsuit vs. US government
FedEx says it overpaid more than $89 million in taxes due to government rules it claims exceed regulatory authority, and the company wants a refund, according to a lawsuit filed Monday by the Memphis delivery giant.
The Internal Revenue Service rules, made final in 2019, kept FedEx from claiming $89 million in foreign tax credits for taxes FedEx and its foreign affiliates paid, the lawsuit said. The specific rules in question are section 965 of the Internal Revenue Code , which affect those with ownership interests in certain foreign corporations.
Happening on Twitter
I wrote about a wild recent interview with the very sketchy Republican running for the Texas Railroad Commission, t… https://t.co/SuJhc4R013 KateAronoff (from Brooklyn, NY) Fri Oct 30 14:31:07 +0000 2020
Texas' oil and gas regulatory board has been dominated by Republicans for 25 years. This year Democrats think the… https://t.co/ovb7LezDDY rebekahallen (from Austin, TX) Fri Oct 30 18:48:01 +0000 2020
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