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IRS Issues Final Regulations on Electing Small Business Trusts

Posted by on September 6th, 2019

: Thanks to the Tax Cuts and Jobs Act (TCJA), a Nonresident Alien (NRA) is now permitted to be a potential current beneficiary of an Electing Small Business Trust (ESBT) [IRC Sec. 1361(c)(2)(B)(v)]. Recently, the IRS issued final regulations (TD 9868) that ensure S corporation income will continue to be subject to U.S. federal income […]

Foreign Reporting—IRS Issues Final Regulations on GILTI and Subpart F Income:

Posted by on August 31st, 2019

The IRS has released final regulations on determining the amount of Global Intangible Low-taxed Income (GILTI) included in the gross income of certain U.S. shareholders of foreign corporations, including U.S. shareholders that are members of a consolidated group. The final regulations also address the determination of a U.S. shareholder’s pro rata share of a controlled […]

Final Regulations on Charitable Contributions and SALT Credits

Posted by on August 24th, 2019

The IRS has issued final regulations (TD 9864) that require taxpayers to reduce their charitable contribution deductions by the amount of any SALT credits they receive or expect to receive in return. The final regulations, which largely follow rules proposed by the IRS in August 2018, provide exceptions for dollar-for-dollar state tax deductions and tax […]

TAX COURT FINDS INCOME FROM AUTHOR’S BRAND SUBJECT TO SELF-EMPLOYMENT TAX

Posted by on August 18th, 2019

Slaughter, TC Memo 2019-65 The Tax Court held that a successful author’s brand was part of her trade or business. As a result, all of her income from her publishing contracts was derived from her trade or business of being a writer and was subject to self-employment tax. Background. Code Sec. 1401(a) imposes a tax […]

IRS Encourages Taxpayers to Renew ITINs

Posted by on August 6th, 2019

The IRS is encouraging individuals with expiring Individual Taxpayer Identification Numbers (ITINs) who expect to have a filing requirement in 2020 to start the renewal process early to avoid refund delays next year. ITINs that haven’t been used on a return at least once in the last three consecutive years will expire 12/31/19. Also, ITINs […]