November 6th, 2018 by Kim Chen
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. […]
November 2nd, 2018 by Kim Chen
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 […]
October 31st, 2018 by Kim Chen
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 […]
August 31st, 2018 by Kim Chen
Small business owners are always looking for easy ways to lower their taxes. Here’s a simple, but effective, tax planning technique that’s available under the Tax Cuts and Jobs Act (TCJA) for 2018 through 2022. To take advantage, you need to purchase a “heavy” vehicle, work from a qualifying home office and keep detailed business […]
August 24th, 2018 by Kim Chen
A recent Congressional Research Service (CRS) report examines the concept of small business tax benefits, lists what it considers the major small business tax benefits that have a general application, and analyzes what it considers the main arguments for and against federal support for small business. Small business tax benefits, generally. The federal tax burden […]
August 20th, 2018 by Kim Chen
The Tax Cuts and Jobs Act (TCJA) imposes a new limitation on deductions for business interest expense. This is a permanent change for tax years beginning in 2018 and beyond. Will your business be affected? Here’s what you need to know. How Have the Rules Changed? Under prior law, some corporations were subject to the […]
August 10th, 2018 by Kim Chen
The IRS has released proposed reliance regulations (REG-107892-18) on the new Qualified Business Income (QBI) deduction under IRC Sec. 199A. The proposed regulations are divided into six substantive sections and provide guidance on calculating the deduction and applying various antiabuse provisions. The IRS also has issued Notice 2018-64 , which proposes a revenue procedure that […]
June 30th, 2018 by Kim Chen
A PCAOB official said more audit engagement teams today are including cybersecurity when they do a risk assessment of a client. The auditor’s increased scrutiny about whether cybersecurity breaches have affected financial reporting or internal controls comes as the frequency and severity of cyberattacks have increased. PCAOB inspectors are seeing an increasing number of audit […]
June 25th, 2018 by Kim Chen
Michael Erman, Tom Bergin, Reuters As reported by Reuters, the corporate tax cut enacted in the Tax Cuts and Jobs Act (TCJA; P.L. 115-97, 12/22/2017) was in part designed to help dissuade U.S. companies from moving profits overseas, but may instead make the practice a lot more rewarding. Under pre-TCJA law, companies which shifted profits […]
June 22nd, 2018 by Kim Chen
Jones, Bell, Abbott, Fleming & Fitzgerald, LLP v. U.S., (DC CA 6/15/2018) 121 AFTR 2d 2018-860 A district court has concluded that a partnership failed to sustain its burden of proof to show that it timely requested an extension of time to file and that IRS improperly assessed a failure-to-file penalty under Code Sec. 6698 […]