Federal Tax Update with Lynn Nichols #44
Lynn Nichols Federal Tax Update Podcast
August, 16 2019, Episode 44
Listen as Lynn Nichols provides commentary on 4 Items pertaining to current developments in U.S. tax law.
The IRS granted an extension for a limited liability company to make a section 336(e) election regarding the LLC’s acquisition of the stock of an S corporation from an S corporation shareholder.
[LTR 201930001, 4/29/2019, rel. 7/26/2019]
The IRS ruled that an S corporation whose shareholders disagreed over the business operation could form two new S corporations and contribute half of the assets to each in liquidation of the parent company without triggering gain and that the earnings and profits and accumulated adjustment accounts of the new companies will be allocated under section 312(h).
[LTR 201930011, 4/30/2019, rel. 7/26/2019]
The IRS has issued guidance (Rev. Proc. 2019-33) that allows a taxpayer to make a late election, or to revoke an election, under section 168(k) for some property acquired by the taxpayer after September 27, 2017, and placed in service by the taxpayer during its tax year that includes September 28, 2017.
[Rev. Proc. 2019-33; 2019-34 IRB 1, 7/31/2019]
The IRS updated a prior international practice unit on how the sourcing rules apply to nonresident aliens to incorporate changes made by the Tax Cuts and Jobs Act for tax years beginning after December 31, 2017.