IRS Updates
The IRS recently released proposed regulations under tax code Section 959, offering long-awaited guidance on previously taxed earnings and profits (PTEP). These proposed rules address core aspects of the PTEP framework, resolving longstanding questions and implementing changes introduced by the 2017 Tax Cuts and Jobs Act (TCJA). What Is PTEP, and Why Does It Matter? …
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The IRS is planning to release updated regulations for the tax treatment of research and development (R&D) costs this winter, providing much-needed clarity for companies navigating these complex rules. What’s Coming: Proposed Section 174 Regulations Scott Vance, associate chief counsel for income tax and accounting in the IRS Office of Chief Counsel, recently announced that…
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The ongoing debate around the federal $10,000 state and local tax (SALT) deduction cap is heating up, with states like New York, New Jersey, and Connecticut challenging an IRS rule that limits their workarounds to this cap. The outcome of this legal battle could significantly affect taxpayers in states where SALT obligations exceed the federal…
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The Treasury Department and IRS recently released proposed regulations to clarify the application of the new Corporate Alternative Minimum Tax (CAMT). This development is significant for large corporations, especially as many will face CAMT for the first time on October 15, 2023, the extended corporate tax-filing deadline. What is CAMT? CAMT is designed to ensure…
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As IRS audits become tougher, now is the time for businesses to reevaluate their tax strategies, especially when it comes to transfer pricing. In recent years, the IRS has significantly ramped up its efforts to ensure compliance, particularly targeting multinational companies with complex intercompany transactions. These transactions, known as transfer pricing, are under closer scrutiny,…
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The IRS has recently re-proposed important rules that impact how controlled foreign corporations (CFCs) report foreign currency gains and losses. If your business operates internationally, these changes could significantly affect your U.S. tax obligations. What’s New? On Monday, the IRS introduced new regulations under RIN 1545-BM80, REG-111629-23. These rules outline the specific situations in which…
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As we approach the end of 2024 and prepare for 2025, many partnerships and S corporations are closely watching the potential expiration of key tax provisions that have significantly impacted their tax bills since 2017. The primary concern? The possible end of the 20% deduction for pass-through businesses, a benefit that has provided substantial tax…
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Recent developments from the IRS shed light on the agency’s efforts to manage pandemic-related tax credits. In addition to addressing employee retention tax credit claims, the IRS is also working on building a new e-filing pilot program. Here’s a summary of the latest actions concerning these initiatives. Significant Recovery in Employee Retention Tax Credit Claims …
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As we navigate through the complexities of tax season, businesses need to stay informed about recent developments in tax policies and enforcement. The Internal Revenue Service (IRS) has recently announced significant strides in combating fraudulent claims related to pandemic-era tax refunds, mainly focusing on the Employee Retention Credit (ERC) program. Understanding the Issue The ERC…
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Monetized installment sale transactions are a strategy used in the sale of assets, such as property or businesses, in which the sale proceeds are almost immediately returned to the seller through a series of transactions designed to avoid immediate tax recognition. The IRS has proposed regulations to address what it views as abusive practices within…
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