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Sec. 965 Transition Tax Penalty Relief Issued

The IRS announced relief from late-payment penalties and that it will allow late elections for taxpayers subject to the new Sec. 965 transition tax on deemed repatriated foreign earnings. To read the full article in The Tax Adviser, click: Sec. 965 Transition Tax Penalty Relief Issued. ...

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Official and Unofficial Rules of Engagement with the IRS

Mike Gregory Discusses the Newly Released Five in One Book on Business Valuations and the IRS In this article, Michael Gregory provides some thoughts of how the official IRS rules of engagement are different from the unofficial rules of engagement and introduces how to work with the IRS. The 38 examples in the book provides additional insight. Mike Gregory recommends the book to all business valuation firms ...

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Sec. 965 Transition Tax Penalty Relief Issued

The IRS announced relief from late-payment penalties and that it will allow late elections for taxpayers subject to the new Sec. 965 transition tax on deemed repatriated foreign earnings, which was enacted by P.L. 115-97, known as the Tax Cuts and Jobs Act of 2017. To read the full article in The Tax Adviser, click: Sec. 965 Transition Tax Penalty Relief Issued. ...

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Management Services Agreements

This article briefly discusses the current trends in the practice management industry, as these trends may directly and indirectly affect both the management company and the healthcare entity. This overview of the services provided by practice management groups, is followed by a discussion of the competitive, reimbursement, regulatory, and technological environments in which practice management groups opera ...

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Federal Spending Bill Includes Tax Provisions

The Consolidated Appropriations Act, 2018, H.R. 1625, which is the $1.3 trillion spending bill that Congress passed, contains a few tax-related provisions, including funding for the IRS and technical corrections to various recent pieces of tax legislation.  It also amends the centralized partnership audit regime and changes the Sec. 199A deduction for farmers who sell grain to agricultural cooperatives. To ...

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Do Not Be Too Quick to Discount

A Discount for Controlling Interests This article examines studies and judicial decisions addressing the use of DLOMs where there are controlling, 100% ownership interests, followed by review of a recent client assignment that illustrates the importance of being well versed with the valuation theory in this area. ...

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No One’s Sure Who Qualifies for this $415B Tax Deduction

Congressional Republicans created a juicy new tax break for clients when they rewrote the U.S. tax code late last year.  Three months later, hundreds of thousands of them still do not know if they qualify.  The IRS has said it will provide guidance detailing exactly who is allowed to take the so-called pass-through deduction.  With billions of dollars at stake, business groups are lobbying for the agency to ...

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How is the Section 199A Deduction determined?

Underlying Policy Identified The pass-through entity, that legal entity structure that has given valuators consternation over the years, is back in the news thanks to the Tax Cut and Jobs Acts (TCJA) signed into law at the end of 2017. According to the Joint Commission on Taxation, business owners filed 35.3 million pass-through returns in 2015. Another 1.6 million returns were file by C corporations. The T ...

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Life Insurance Planning After Tax Reform

Tax Overhaul Directly, Indirectly Affects Life Insurance Planning The recent overhaul of U.S. tax law will affect life insurance planning directly through changes to reporting requirements and tax-basis calculations for contracts.  Indirect effects include the likelihood that many clients will no longer need life insurance to pay the federal estate tax, for which the exemption has doubled. To read the full ...

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Rules Would Allow Truncated Taxpayer IDs on Forms W-2

In an effort to reduce identity theft, the IRS issued proposed regulations that would permit employers to use truncated taxpayer identification numbers (TTINs) on Forms W-2, Wage and Tax Statement, issued to employees. To read the full article in The Tax Adviser, click: Rules Would Allow Truncated Taxpayer IDs on Forms W-2. ...

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Reliance on Tax Software Does Not Let Taxpayer Off the Hook

A taxpayer cannot blame tax preparation software for inaccuracies that lead to penalties.  A recent Tax Court case provides a cautionary tale for taxpayers who rely on do-it-yourself tax preparation software to prepare their tax returns.  Craig Smalley provides some insight into this. To read the full article in The Tax Adviser, click: Reliance on Tax Software Does Not Let Taxpayer Off the Hook. ...

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Reasonableness of Shareholder/Executive Compensation

Challenging and Defending Compensation and Use of the Independent Investor Test C corporations and S corporations should pay shareholder/executive compensation based on the fair market value of the executive services rendered—or risk being audited and possibly penalized by the Internal Revenue Service. Forensic analysts can help companies determine reasonable shareholder/executive compensation using free or ...

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IRS Updates Special Per-Diem Rates for Business Travel

Business travelers who incur expenses while traveling away from home have new per-diem rates to use in substantiating certain of those expenses (Notice 2017-54).  The new rates will be in effect from Oct. 1, 2017, to Sept. 30, 2018.  Sally Schreiber, Journal of Accountancy senior editor, explains. To read the full article in the Journal of Accountancy, click: IRS Updates Special Per-Diem Rates for Business ...

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Five Reasons You Should Join a Professional Association

Personal commitment and synchronized teamwork is what it takes to be an active member of professional associations.  The work may not be physically challenging, but when you partner together and work towards a similar goal, you can achieve great things. To read the full article in CPA Practice Advisor, click: Five Reasons You Should Join a Professional Association. ...

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What Proposed Regulations on the Fractions Rule Mean for Tax-Exempt Organizations

Understanding the fractions rule can enable tax-exempt organizations to invest in partnerships that hold interests in debt-financed real property without being subject to the tax on unrelated business income under Section 512.  Michael Hoffman, CPA, Washington, explains. To read the full article in The Tax Advisor, click: What Proposed Regulations on the Fractions Rule Mean for Tax-Exempt Organizations. ...

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Personal Goodwill

The Value of a Business is Not Always What it Seems (Part I of II) Personal goodwill is taxed at the individual capital gains tax rate, not the higher corporate income tax rate. Therefore, a credible personal goodwill calculation can amount to significant tax savings. One that is not adequately defensible invites risk of an audit. Every personal goodwill calculation is unique to each business, and the manag ...

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Accounting Period Planning may Provide Preferred Year

Although some types of entities have required tax years, not all do.  Karen Messner helps you find out how to adopt a tax year other than a calendar year by planning ahead. To read the full article in the The Tax Adviser, click: Accounting Period Planning may Provide Preferred Year. ...

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Using the Option Pricing Method Changes the Standard of Value

Does the IRS or Anyone Care? (Part II of II) Part one of this article presented the “current method” and “option pricing method” (OPM) for allocating value to common stock for 409a valuations, and how these two methods differ in pricing of common stock. Part two examines the implied changes made by OPM and how it affects stakeholders. The article begins with a brief review of the key impacts on the valuatio ...

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Using the Option Pricing Method Changes the Standard of Value

Does the IRS or Anyone Care? (Part I of II) In part one of this two-part article, the author presents the two methods for allocating value to common stock for 409a valuations, and then show how they affect the pricing of common stock. By way of background, to meet FMV, the standard of value requires measuring value under the representation of a hypothetical willing buyer and a hypothetical willing seller, b ...

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