Penalty and Filing Relief on Foreign Earnings Transition Tax

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The Internal Revenue Service (IRS) continues to provide guidance on the implementation of certain provisions within the Tax Cuts and Jobs Act.  Nowhere is this guidance more prolific, and more welcome, than in the international tax provisions of the Act. This week, in News Release IR 2018-131, the IRS has announced that it will waive […]

IRS Takes No Bull on Hobby Loss Rules

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The Internal Revenue Service regularly challenges businesses that are found to generate losses and do not have a profit intent. The specific statute that governs these challenges are known as the “Hobby Loss Rules.” In such challenges, the Internal Revenue Service is trying to prove that the undertaking which has resulted in losses over a […]

IRS Offers Automatic Consent Procedure to Change Accounting Methods

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The Internal Revenue Service issued Rev. Proc. 2018-29 to provide an automatic consent procedure for taxpayers changing to a new accounting method under new standards issued by the Financial Accounting Standards Board (FASB) and the International Accounting Standards Board (IASB) for recognizing revenue from customer contracts. This revenue procedure takes into account concerns and suggestions offered […]

Blended Corporate Income Tax Rate Applies to “Bridging” Tax Years

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The Internal Revenue Service recently released confirmation that Section 15 of the Internal Revenue Code will apply to fiscal year corporations whose tax year “bridges” January 1, 2018 (the day that the new lower corporate income tax rate enacted as part of the Tax Cuts and Jobs Act became effective). The information release IR-2018-99 was […]

IRS Releases Fact Sheet for New Depreciation and Expensing Rules  

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The Internal Revenue Service continues to provide additional guidance on the provisions included in the Tax Cuts and Jobs Act (TCJA), which was enacted in December 2017. The Service recently released Fact Sheet 2018-9, which highlights the new depreciation and expensing rules. These rules generally favor capital investment and taxpayers and could play an important […]

Tax Court Disallows Charitable Deduction of Remainder Interest

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In a very significant case, the United States Tax Court found that a limited liability company (LLC) was not entitled to a charitable contribution deduction for the donation of a remainder interest in real property because it failed to adequately substantiate its claimed deduction. The Form 8283 (appraisal summary for noncash charitable contributions) the LLC […]