CRS REPORT HIGHLIGHTS EXPIRED AND EXPIRING TAX “EXTENDER” PROVISIONS
Posted by Kim Chen on November 16th, 2018
Congressional Research Service report—Tax Provisions That Expired in 2017 The Congressional Research Service (CRS) has updated a report on the 28 temporary tax provisions that, despite being routinely extended on a 1- or 2-year basis, were allowed to expire at the end of 2017. Two additional provisions are scheduled to expire at the end of […]
TAX COURT DETERMINES IF INTEREST INCLUDIBLE IN ESTATE WAS PARTNERSHIP OR ASSIGNEE INTEREST
Posted by Kim Chen on November 11th, 2018
Estate of Streightoff, TC Memo 2018-178 The Tax Court has determined the type and value of an interest that a taxpayer transferred during his lifetime to a revocable trust that had to be included in his estate — a limited partnership interest or an assignee interest in the partnership interest. Background. Generally, State law determines […]
MANY RETIREMENT PLAN DOLLAR LIMITS INCREASE FOR 2019
Posted by Kim Chen on November 6th, 2018
Notice 2018-83, 2018-47 IRB; IR 2018-211, 11/1/2018 IRS has announced the 2019 cost-of-living adjustments (COLAs) with respect to retirement plan limits. Many limits, which are adjusted by reference to Code Sec. 415(d), are changed for 2019 since the increase in the cost-of-living index met the statutory thresholds that trigger their adjustment. However, others remain unchanged. […]
PROPOSED REGULATIONS REDUCE SECTION 956 INCLUSION FOR CERTAIN CORPORATIONS
Posted by Kim Chen on November 2nd, 2018
Under IRC Sec. 956, U.S. shareholders of a Controlled Foreign Corporation (CFC) are taxed on their prorata share of the CFC’s increase in earnings invested in U.S. property. However, the IRS has determined that newly enacted IRC Sec. 245A, which provides a deduction for certain foreign-sourced dividends, creates inconsistencies between actual dividends and Section 956 […]
S CORPORATION’S PAYMENT OF INSURANCE PREMIUM WAS PROPERTY DISTRIBUTION TO SHAREHOLDER
Posted by Kim Chen on October 31st, 2018
Machacek, Jr. v. Comm., (CA6 10/12/2018) 122 AFTR 2d 2018-6269 In a case of first impression, the Court of Appeals for the Sixth Circuit, reversing the Tax Court, has held that the economic benefits flowing to the taxpayers, husband and wife, from the payment of a $100,000 premium on the husband’s insurance policy had to […]
