Federal Tax Update with Lynn Nichols #43
Lynn Nichols Federal Tax Update Podcast
August, 01 2019, Episode 43
Listen as Lynn Nichols provides commentary on 8 Items pertaining to current developments in U.S. tax law.
Final regulations explaining how organizations should notify the IRS of their intent to operate as section 501(c)(4) social welfare entities are almost unchanged from the temporary and proposed regs and generally reject recommendations from the public.
[Tax Notes Today, 7/22/2019, Article by Fred Stokeld]
In partially redacted technical advice, the IRS concluded that a deemed distribution of a partnership interest in an assets-over merger of two partnerships is considered an exchange that requires a mandatory downward basis adjustment under section 743(b) when the resulting partnership has a substantial built-in loss.
[TAM 201929019, 4/30/2019, rel., 7/19/2019]
The IRS Large Business and International Division has approved six new compliance initiatives that were identified through LB&I data analysis and suggestions from IRS employees.
[LB&I Div. Announcement on July 19,2019]
Treasury and the IRS are developing proposed rules on the application of the $10,000 cap on the state and local tax deduction to passthroughs, and practitioners fear the guidance will seek to invalidate an emerging SALT cap workaround.
[Tax Notes Today, 7/23/2019, Article by Amy Hamilton]
About 110,000 passthroughs are participating in Connecticut’s workaround to the $10,000 cap on the state and local tax deduction featuring an entity-level tax and offsetting state credit for members, according to Revenue Commissioner Scott Jackson.
[Tax Notes Today, 7/26/2019, Article by Amy Hamilton]
The IRS has reminded (IR-2019-131) professional tax return preparers that federal law requires them to create a written information security plan to protect their clients’ data. This release is one in a series of the "Tax Security 2.0 -- Taxes-Security Together" campaign.
The government punted on the treatment of self-charged interest in the proposed business interest limitation regulations, forcing practitioners to take a best guess on its treatment without authority to rely on.
[Tax Notes Today, 7/26/2019, Article by Eric Yauch]
The IRS has issued guidance (Rev. Proc. 2019-32) granting an extension to eligible partnerships to file a superseding Form 1065, “U.S. Return of Partnership Income,” and furnish a corresponding Schedule K-1 (Form 1065), “Partner’s Share of Income, Deductions, Credits, etc.,” to each of its partners.
[Rev. Proc. 2019-32; 2019-33 IRB 1, 7/25/2019]
A U.S. district court, in a broader breach of contract case, awarded damages under section 7434 to an employee who claimed her employer submitted false information to the IRS by classifying her as an independent contractor rather than as an employee.
[Valerie Vanderbilt v. Boat Bottom LLC, et al.; USDC S FL Key West Div., No. 4:18-cv-10261]