The IRS proposed new rules under the global intangible low-taxed income (GILTI) provision (Sec. 951A) added by the Tax Cuts and Jobs Act. Sec. 951A requires U.S. shareholders of controlled foreign corporations (CFCs) to include in their gross income their GILTI income for that tax year (the inclusion amount). The new provision applies to tax years of foreign corporations beginning after Dec. 31, 2017, and to the U.S. shareholders’ tax years within which the foreign corporations’ tax years end. To read the full article in the Journal of Accountancy, click: IRS Issues Proposed Regs for GILTI Inclusions.
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The proposed rules include a way that taxpayers can group or aggregate separate trades or businesses and an anti-abuse rule designed to prevent taxpayers from separating out parts of an otherwise disqualified business in an attempt to qualify those separated parts for the Sec. 199A deduction. To read the full article in the Journal of Accountancy, click: Qualified Business Income Deduction Regulations Proposed.
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That You as a Business Valuer Need to Know About On August 8, 2018, the Service released proposed 199A regulations. Those regulations are important and mark a dramatic change from the prior tax regime. Another change that also marks a departure involves the release of final regulations for non-cash charitable deductions. In this article, the author discusses the latter.
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The IRS issued a draft version of the 2019 Form W-4, Employee’s Withholding Allowance Certificate, and instructions for the form, in an attempt to further simplify the task of determining income tax withholding for individual taxpayers after the passage of P.L. 115-97, known as the Tax Cuts and Jobs Act of 2017 (TCJA). The TCJA eliminated personal exemptions, increased the standard deduction, increased the child tax credit, limited or discontinued certain deductions, and changed the tax rates and brackets. To read the full article in The Tax Advisor, click: Draft 2019 Form W-4 and Instructions Posted.
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The IRS released a draft Form W-4, Employee’s Withholding Allowance Certificate, and its instructions, for individual taxpayers to use to determine their income tax withholding for 2019. To read the full article in The Tax Adviser, click: Draft 2019 Form W-4 and Instructions Posted.
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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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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 that have a library and those that prepare reports for federal tax purposes. Parts One and Two of the book discuss the IRS structure, process, and how to resolve conflicts with the IRS;…
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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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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 operate.
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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 read the full article in the Journal of Accountancy, click: Federal Spending Bill Includes Tax Provisions.
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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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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 open the doors to the deduction as widely as possible. To read the full article in FinancialPlanning, click: No One’s Sure Who Qualifies for this $415B Tax Deduction.
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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 TCJA has essentially created a flat tax of 21% for corporations. There is a lot of buzz about “199A”, a new Internal Revenue Code section and deduction and the introduction of a new term,…
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Book Review by Michael D. Pakter, CPA, CFF, CGMA, CFE, CVA, MAFF, CA, CIRA, CDBV In this article, Michael D. Pakter, writes a brief review of Michael Gregory’s latest book, Business Valuations and the IRS: Five Books in One.
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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 article in Wealth Management, click: Life Insurance Planning After Tax Reform.
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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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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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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 fee-based compensation data, with consideration of statutory authority and judicial precedent. This discussion (1) summarizes the federal income tax statutes and judicial precedents related to shareholder/executive compensation, (2) provides a list of frequently relied upon executive compensation data sources, and (3) reviews important issues presented in…
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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 Travel.
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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.