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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Court Decision Affects Real Estate Purchase Price And Depreciation

Recent Tax Court Decision Rebuffs Allocation of Purchase Price to Depreciable and Non-depreciable Real Estate by Taxpayer In a recent Tax Court decision, Nielsen v. Commissioner, T.C. Summ. Op. 2017-31 (May 8, 2017), the court found that the taxpayer’s allocation of the purchase price of rental real estate between land and buildings was unreasonable. Instead,…

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Research Tax Credit

Documentation Requirements By Functional Areas For Research Credit

Substantiating Research Credit Expenditures by Functional Area Two of our recent articles have focused on different aspects of the research credit under Internal Revenue Code (IRC) §41 which rewards taxpayers for engaging in qualified research activities by providing a tax credit equal to a percentage of certain eligible expenses. The first article focused on the…

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IRS Partnership Audit Regulations Reissued

IRS Reissues Centralized Partnership Audit Regime Regulations In November of 2015, Congress passed and Pres. Obama signed into law the Bipartisan Budget Act. Section 1101 of the legislation introduced a new audit regime for partnerships to replace the former rules instituted under the Tax Equity and Fiscal Responsibility Act of 1982 (TEFRA). Back in October…

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The Tax Rate Debate

As the summer wears on the Trump Administration and Congress are coming close to initiating their push for major tax reform legislation. If this task is accomplished, it will likely be the most significant change to the Internal Revenue Code (IRC) since the tax reform package passed and signed into law in 1986 during the…

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Property Transfer Taxation

IRS Changes Transfer of Property Rules

Temporary IRS Regulations Change Rules for Transfers of Property by U.S. Persons to Partnerships with Related Foreign Partners Internal Revenue Code (IRC) §721(a) provides, as a general rule, that a taxpayer does not recognize built-in gain on the contribution of appreciated property to a partnership. Rather the partnership assumes a carry-over basis in that property.…

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