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  • Article

    IRS Issues Final Regulations On Allocation Of Mortgage Insurance Premiums

    The IRS has finalized regulations (T.D. 9588) that explain how to allocate prepaid qualified mortgage insurance (QMI) premiums.
    United StatesTax
    Grant Thornton LLP
    Grant Thornton LLP
  • Article

    IRS Issues Final Regulations Related To Foreign Currency Hedging Transactions

    The final regulations provide for the treatment of an integrated transaction when the taxpayer disposes of or otherwise terminates all or a portion of the QDI or the hedge before maturity.
    United StatesTax
    Grant Thornton LLP
    Grant Thornton LLP
  • Article

    IRS Issues Final Rules For Qualified Longevity Annuity Contracts Under Defined Contribution Plans

    The IRS on July 2 issued final regulations relating to the purchase of qualified longevity annuity contracts under qualified defined contribution retirement plans.
    United StatesTax
    Grant Thornton LLP
    Grant Thornton LLP
  • Article

    IRS Issues Foreign Tax Credit Guidelines Under Section 901(M)

    Treasury and the IRS intend to issue regulations addressing the application of Section 901(m) to disposition of assets following covered asset acquisitions.
    United StatesTax
    Grant Thornton LLP
    Grant Thornton LLP
  • Article

    IRS Issues Guidance For Claiming Production Tax Credit

    The IRS issued Notice 2013-60, seeking to clarify prior guidance, Notice 2013-29, related to when a taxpayer has satisfied the requirements necessary to claim the renewable electricity production tax credit (PTC) under Section 45.
    United StatesTax
    Grant Thornton LLP
    Grant Thornton LLP
  • Article

    IRS Issues Guidance On Dividends And Dividend Equivalents Under Section 162(m)

    The IRS has issued guidance (Rev. Rul. 2012-19) on how dividends and dividend equivalents are treated for purposes of the $1 million compensation deduction limit under Section 162(m).
    United StatesTax
    Grant Thornton LLP
    Grant Thornton LLP
  • Article

    IRS Issues Guidance On Suspension Of Retirement Benefits

    The sponsors of those plans are permitted to reduce the pension benefits payable to plan participants and beneficiaries if certain conditions are satisfied.
    United StatesTax
    Grant Thornton LLP
    Grant Thornton LLP
  • Article

    IRS Issues Notice On Treatment Of U.S. Shareholders Owning PFIC Stock Through Taxexempt Organizations Or Accounts

    The IRS intends to amend regulations to provide guidance concerning the treatment of U.S. persons that own stock of a passive foreign investment company.
    United StatesTax
    Grant Thornton LLP
    Grant Thornton LLP
  • Article

    IRS Issues Rehabilitation Credit Safe Harbor

    The IRS has issued guidance that responds to Historic Boardwalk Hall, LLC v. Commissioner, in which the Third Circuit held that an investor in a partnership who did not have any meaningful downside risk or upside potential was not a bona fide partner for federal tax purposes, and was therefore not entitled to an allocation of 99.9% of the historic rehabilitation tax credits under Section 47.
    United StatesTax
    Grant Thornton LLP
    Grant Thornton LLP
  • Article

    IRS Memorandum Addresses Application Of Like-Kind Exchange Rules And Aircraft Held For Trade Or Business Use

    In a recent Internal Legal Memorandum to the field, the IRS National Office determined that an aircraft was held for productive use in a trade or business for purposes of applying the Section 1031 nonrecognition provisions.
    United StatesTax
    Grant Thornton LLP
    Grant Thornton LLP
  • Article

    IRS Postpones New Requirements For Estates To Report Asset Values

    The IRS postponed the new asset value reporting requirements for estates until Feb. 29, 2016.
    United StatesTax
    Grant Thornton LLP
    Grant Thornton LLP
  • Article

    IRS Previews Proposed Automatic Method Change Procedures For Revenue

    The IRS is requesting comments on a proposed revenue procedure, which, if finalized, would provide automatic consent to certain tax accounting method changes for revenue...
    United StatesTax
    Grant Thornton LLP
    Grant Thornton LLP
  • Article

    IRS Proposes Regulations On Compensation Deduction Limit For Health Insurers

    The IRS recently issued proposed regulations to provide guidance on the new rule that limits compensation deductions for health insurance providers to $500,000 per employee.
    United StatesTax
    Grant Thornton LLP
    Grant Thornton LLP
  • Article

    IRS Proposes Regulations Under Section 83

    The IRS recently proposed regulations (REG-141075-09) under Section 83 to clarify and make changes to the current regulations.
    United StatesTax
    Grant Thornton LLP
    Grant Thornton LLP
  • Article

    IRS Provides Guidance On Early Adoption Of CbC Reporting

    The IRS issued final regulations (TD 9773) on June 29, 2016, that will require U.S. multinationals with more than $850 million in revenue to report specific information on a CbC basis.
    United StatesTax
    Grant Thornton LLP
    Grant Thornton LLP
  • Article

    IRS Provides Guidance On Pension Funding Stabilization

    The IRS provided guidance on the changes to the funding stabilization rules for single-employer pension plans that were made by the Highway and Transportation Funding Act of 2014.
    United StatesTax
    Grant Thornton LLP
    Grant Thornton LLP
  • Article

    IRS Provides Guidance On Signing Of POAs For Certain LLCs

    The IRS ruled in a chief council advice memorandum (CCA 2015-22-005) that a corporate officer of a common parent of a consolidated group must sign Form 2848...
    United StatesTax
    Grant Thornton LLP
    Grant Thornton LLP
  • Article

    IRS Releases Draft Instructions For Net Investment Income Tax Form

    The IRS has released draft instructions for trusts, estates and individuals to calculate and pay their Section 1411 net investment income (NII) tax liability and for partnerships and S corporations to report information on NII to shareholders and partners.
    United StatesTax
    Grant Thornton LLP
    Grant Thornton LLP
  • Article

    IRS Releases New Guidance On Corrections Program For Qualified Retirement Plans

    The IRS has issued Rev. Proc. 2013-12 to provide updated guidance on the voluntary correction program for employee retirement plans.
    United StatesTax
    Grant Thornton LLP
    Grant Thornton LLP
  • Article

    IRS Removes Automatic Extension For Filing Forms W-2

    Electronically filed information returns are due by March 31, but with extensions, these returns may be due by the end of May.
    United StatesTax
    Grant Thornton LLP
    Grant Thornton LLP

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