NOL Provisions In Final Tax Reform Bill

NOL Provisions in Tax Cuts and Jobs Act This article will focus on the changes made by the recently enacted Tax Cuts and Jobs Act to the provisions regarding net operating losses (NOLs). These significant changes are outlined in the table below: NOL Provisions in Final Tax Reform Bill   Current Law Tax Bill NOL…

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IRS Finalizes Form Modifications Disregarded Entities with Single Foreign Owner

IRS to Finalize Form Modifications for Taxpayer Compliance with Regulations on U.S. Disregarded Entities with a Single Foreign Owner This past April we published a blog article regarding the final regulations released by the Internal Revenue Service (IRS) that apply to U.S. disregarded entities (hereafter referred to as “U.S. DEs”) wholly-owned by a foreign person.…

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Centralized Partnership Audit Regime: International Regulations

As the 2018 implementation of the centralized partnership audit regime passed under §1101 of the Bipartisan Budget Act (BBA) of 2015 is fast approaching, the Internal Revenue Service (IRS) is releasing a myriad of regulations to provide a framework for compliance by taxpayers. This new audit regime generally applies any tax burden or penalty arising…

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Tax Reform Cost Recovery Provisions

Cost Recovery Provisions in Tax Reform   Both the House and Senate passed versions of tax reform make substantial revisions to the cost recovery provisions affecting businesses in the Internal Revenue Code (IRC). These proposed changes are outlined in the following chart.   Cost  Recovery Provisions in Senate and House Versions of Tax Reform  …

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Tax Reform Legislation: Impacts on the Real Estate Industry

Tax Reform Legislation: Impacts on the Real Estate Industry     House vs. Senate Bill Specific to Real Estate Industry   House Senate Tax Rates on Pass-Through Entities 25% maximum tax rate on qualified business income (QBI) of partnerships, S corporations, and sole proprietorships; QBI is 100% of net business income from passive activities and…

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Tax Reform Legislation will Overhaul NOL Provisions

Both the House and Senate versions of tax reform propose significant changes to the treatment of net operating losses (NOLs). The current tax code generally allows a two-year carry back deduction of NOLs and a carry forward of 20 years to offset future income.   The House bill proposes the following changes: NOLs cannot offset…

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Presidential Tax Reform Framework

New Presidential Tax Reform Framework

Tax Reform Framework Released by Trump Administration and its Congressional Allies On September 27th, the Trump administration, the House Committee on Ways and Means, and the Senate Finance Committee released a unified framework with the stated intent to achieve “pro-American, fiscally-responsible tax reform.” The framework expounds upon the four principles of tax reform released by…

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IRS Tax Regulations

Transfer of Intangibles to Foreign Corporations IRS Regulations

Final IRS Regulations on Transfers of Intangibles to Foreign Corporations On December 16, 2016, the Internal Revenue Service (IRS) published final regulations regarding transfers of intangible assets, including goodwill and going concern value, by U.S. persons to foreign corporations. These new regulations modify regulations under Internal Revenue Code (IRC) §§367(a) and (d) to ensure that…

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IRS Relief For Hurricane Harvey Victims

IRS to Provide Relief for Those Affected by Hurricane Harvey Due to Pres. Trump’s major disaster declaration for the state of Texas in response to Hurricane Harvey, the Internal Revenue Service (IRS) has announced that tax relief will be made available to those affected by the storm. Specifically, the IRS will be postponing certain deadlines…

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Executive Order Endangers Eight Significant IRS Regulations

Executive Order Endangers Eight Significant IRS Regulations On April 21, 2017, Pres. Donald Trump issued Executive Order 13789 on Identifying and Reducing Tax Regulatory Burdens. The order directed the Secretary of the Treasury to review all “significant” tax regulations issued by the Treasury Department on or after January 1, 2016. This review will culminate with…

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