On February 25, the IRS issued a warning to taxpayers seeking to secure missed domestic production activities deductions under the now obsolete section 199. The IRS maintains that a high percentage of such claims are not...more
Yes, it sounds odd. It is also seems to be at odds with this blog’s constant refrain of “Thou shalt not pursue any undertaking solely for tax purposes, but thou shalt first consider the business purpose for such...more
As discussed in our prior alert, the proposed Section 199A regulations provided welcome guidance regarding the application of the pass-through deduction across related entities but left many questions unanswered. ...more
When proposed regulations under new Section 199A were issued regarding the deduction for pass-through entities, many real estate professionals were frustrated by the use of Section 162 to define a “trade or business” eligible...more
The IRS has released the long-awaited final regulations on the Section 199A qualified business income deduction. Along with the regulations, the IRS released Notice 2019-07 that contains a proposed revenue procedure with a...more
In early August, the Internal Revenue Service (IRS) issued proposed regulations under the Tax Cuts and Jobs Act (TCJA) that provide guidance to owners of pass-through businesses as to eligibility for a federal tax deduction...more
Section 199A of the Internal Revenue Code provides Individual Taxpayers a deduction for the Qualified Business Income (QBI) of a qualified trade or business operated directly or through a pass-through entity....more
The Bracewell Tax Report is a periodic publication focused on developments in federal income tax law, including the recently enacted Tax Cuts and Jobs Act, with emphasis on how such developments impact the energy, technology...more
Section 199A was added to the Internal Revenue Code by The Tax Cuts and Jobs Act (“TCJA”), enacted in December 2017. It provides taxpayers, other than corporations, with an income tax deduction of up to 20% of Qualified...more
What follows is the first in a series of posts that will review the long-awaited proposed regulations under Sec. 199A of the Code – the “20% deduction” – which was enacted by the Tax Cuts and Jobs Act to benefit the...more
On August 8, 2018, the U.S. Department of the Treasury (the "Treasury") and the Internal Revenue Service (the "IRS") issued proposed regulations regarding the "pass-through deduction" for qualified trade or business income...more
Congress released the "Tax Cuts and Jobs Act" on late Friday evening, Dec. 15, 2017. This version of the bill is the result of a conference committee process to marry the different bills previously passed by the U.S. House of...more
Taxpayers’ section 199 computer software deductions are under attack! The issue is being coordinated within the IRS, and at Exam and Appeals taxpayers are running into a brick wall. A resource-starved IRS is trying to treat...more
On April 1, the Internal Revenue Service (IRS) released ILM 201313020 (ILM) in response to an IRS Appeals Division request. It concludes that planning and development activities undertaken by a publisher of books and other...more
In a recently released Chief Counsel Advice, the IRS National Office concluded that a publisher’s activities in producing an “electronic” version of books that were “printed” by a third party did not constitute qualifying...more