The law known as the Tax Cuts and Jobs Act of 2017 (TCJA) made many significant changes to the international tax regime. One important change is Sec. 250, which was enacted by Section 14202(a) of the TCJA, and generally provides a domestic C corporation (1) a deduction for its foreign-derived intangible income (FDII) for the tax year, and (2) a deduction for its Sec. 951A global intangible low-taxed income (GILTI) inclusion for the tax year. To read the full article in The Tax Advisor, click: Foreign-Derived Intangible Income Guidance Addresses Many Open Questions.
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C corporations with foreign-derived intangible income can benefit from a 37.5% deduction. This article provides guidance and dispels general misconceptions or mistaken impressions regarding this new deduction. Further, the article provides an overview of the FDII concepts and pertinent definitions and terminology, as well as practice tips and implications for claiming the FDII deduction, for which many companies are not certain whether they qualify. To read the full article in Journal of Accountancy, click: Understanding the FDII Deduction.
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The Tax Court also denies capital gain treatment but allows business deductions for a taxpayer’s subsequent shooting activity. Recently, the Tax Court ruled that an individual who received income as a nominee of a C corporation was not subject to the hobby loss rules of Sec. 183. To read the full article in the Journal of Accountancy, click: Salesman’s Termination Payment Held Not For Goodwill.
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On Business Valuations The Tax Cuts and Jobs Act (TCJA) changes many aspects of how business analysts perform valuations. Upon passing of the TCJA, Jim Hitchner moved quickly to gather and disseminate information about the TCJA and its effect on business valuation. He has written two comprehensive articles in Issues 72 and 73 of Financial Valuation and Litigation Expert. The information in this article summarizes some of the main points expressed in those publications.
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Understanding Both Sorts of Appraisal is Critical to Valuing Minority, Partial Interests in Holding Entities that Own Real Estate and Other Assets that are Gifted, Sold, or Otherwise Transferred Randolph Glennon, MAI, CRE, MBA, and president of Eastern Appraisal & Consulting in Portland, Maine, explains in the New England Real Estate Journal why there’s growing need for appraisers who understand both real estate appraisal and business appraisal. An excerpt: