As amended by the Tax Cuts and Jobs Act (TCJA), section 163(j) of the Internal Revenue Code (the Code) provides that a taxpayer’s interest expense is deductible only to the extent of the sum of: (i) the taxpayer’s interest...more
1/27/2021
/ Biden Administration ,
CFCs ,
Coronavirus/COVID-19 ,
GILTI tax ,
Income Taxes ,
Internal Revenue Code (IRC) ,
IRS ,
Proposed Regulation ,
Regulatory Freeze ,
Subpart F ,
Tax Cuts and Jobs Act ,
Taxable Income ,
U.S. Treasury
As amended by the Tax Cuts and Jobs Act (TCJA), section 163(j) of the Internal Revenue Code (the Code) provides that a taxpayer’s interest expense is deductible only to the extent of the sum of: (i) the taxpayer’s interest...more
On July 9, 2020, the US Department of the Treasury (Treasury) and Internal Revenue Service (IRS) released Final Regulations (Final Regulations) that provide guidance on the section 250 deduction for foreign-derived intangible...more
Proposed regulations under Sections 863(b) and 865(e)(2) implement changes by TCJA to section 863(b), the primary sourcing provision for income from the sale of inventory produced by a taxpayer without and sold within the...more
Many states and localities give incentives for business to move or transact in their locations. There has always been a question of whether these incentives are taxable income under federal income tax law. Internal Revenue...more
4/11/2019
/ Capital Assets ,
Community Development ,
Economic Development ,
Grants ,
Municipalities ,
Non-Taxable Income ,
State and Local Government ,
Tax Court ,
Tax Cuts and Jobs Act ,
Tax Deductions ,
Tax Reform