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Cost Recovery Provisions

Cost Recovery Provisions in Final Tax Reform Bill

The final version of the tax reform bill, which was passed by Congress on December 20 and signed into law by Pres. Trump on December 22, makes a variety of changes to the cost recovery provisions in the Internal Revenue Code (IRC). The following table lays out the enacted provisions pertaining to cost recovery:  …

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LLC Tax Filing Consequences

Single-Member vs. Multi-Member LLCs: Federal Tax Filing Consequences

The limited liability company (LLC) form of business organization is extremely popular and provides many advantages to its members. The benefits of this form of organization includes limited liability for its owners (known as members) and the avoidance of the double taxation which afflicts corporations. Members can also participate in the management of the entity…

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Entertainment Tax Deductions

Major Meals, Entertainment, Vehicle Deduction Changes

The Party’s Officially Over: Meals, Entertainment, and Other Fringe Expense Changes in Final Tax Reform Bill Changes to Meals, Entertainment, and Other Fringe Expenses in Final Tax Bill   Current Law Tax Bill Entertainment Expenses Deduction allowed for 50% of the ordinary and necessary expenses for activities considered entertainment, amusement, or recreation, or facility used…

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Centralized Partnership Audit Regime

The ALL new Centralized Partnership Audit Regime is here! What to do now: Action Steps, Elections, and more Beginning in 2018 the IRS will now conduct partnership audits at the entity level instead of opening separate audits on each of the individual partners. Consequently, we, along with most tax professionals, recommend that partnerships initiate certain…

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Partnership Audit Tax

Tiered Partnership Regulations – New Audit Rules

IRS Releases Tiered Partnership Regulations as Part of Implementation of New Partnership Audit Rules On December 19, 2017, the IRS published the latest regulations implementing the centralized partnership audit regime passed into law as part of the Bipartisan Budget Act (BBA) of 2015. These proposed regulations provide rules on the ability of pass-through partners to…

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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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Partnership Targeted Capital Accounts

Partnership Targeted Capital Accounts: Part III

Introduction Part I of this article described the overall concept behind the targeted capital account approach to allocating taxable income and loss. Part II presented a general example of how a targeted capital account analysis functions when a partnership agreement provides for preferences with respect to partnership distributions. This Part III will address a variety…

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