Partnerships – TMP Must Be a Partner
With April 15th rapidly approaching, I thought I would address a common question that I receive this time of year. Who can be the tax matters partner of a partnership?...By: Amanda Wilson
View ArticleTax Day Has Passed, But Don’t Forget June 30th!
Now that April 15th has passed, you might be thinking that you are done with tax filings for the year. But, if you have any foreign bank accounts or financial assets overseas, you may be required to...
View ArticleNew REIT Bill Coming?
In late April, Senator Orrin Hatch introduced Senate bill 915, the Real Estate Investment and Jobs Act of 2015. When a foreign person invests in property in the U.S., that person is subject to U.S. tax...
View ArticleBusiness Tax Reform High Priority
Last week, I was at the ABA Tax Section meeting in DC, and one refrain that I heard over and over is that tax reform is a major priority for Congress. The Obama administration has basically shut down...
View ArticleNFL Gives Up Tax-Exempt Status
Earlier this year, I posted about the possibility that the NFL may lose its tax exempt status. The NFL has decided instead to give up its tax-exempt status. It has been estimated that the tax-exempt...
View ArticleIRS Presses Pause on Issuing Rulings
The IRS announced earlier this week that it may temporarily stop reviewing private letter ruling requests on the issue of whether a spin-off qualifies as tax-free under Section 355. More specifically,...
View ArticleIRS Website Breached
The IRS announced yesterday that criminals had used the “get transcript” application on its website to gain access to the tax information of approximately 100,000 taxpayers. The IRS has temporarily...
View ArticleSki Lift Towers Held to Be Good REIT Asset
In order to qualify for the tax advantages available for real estate investment trusts (“REITs”), the majority of a REIT’s assets must qualify as “real property”. As the areas that REITs are investing...
View ArticleFiling Form 3115? New IRS Guidance
If you are about to file a Form 3115 requesting a change in accounting method, you should be aware that the IRS released new guidance yesterday in the form of Revenue Procedure 2015-33. This new...
View ArticleTreasury to Narrow Scope of “May Company” Regs
In the 1990s, Treasury issued proposed regulations under Regulation Section 1.337(d)-3 commonly known as the “May Company” regulations. These proposed regulations dealt with situations in which a...
View ArticleAnother REIT Ruling by the IRS – This Time, Billboards
The IRS has released yet another private letter ruling (Letter 201522002) in the REIT area. This time, the IRS addressed the REIT treatment of income from the rental of outdoor advertising space (i.e.,...
View ArticleDidn’t File an FBAR? Don’t Panic
As I discussed in a prior blog post, if you have more than $10,000 in a foreign bank account, you are obligated to file Form 114 (commonly known as an FBAR). Failure to make this filing can result in...
View ArticleForeign Citizen Living In the U.S.? Remember Your FBAR
If you are a foreign citizen that is considered to be a resident for U.S. income tax purposes, you need to be aware that your U.S. tax filing obligation is not limited to the income tax return. U.S....
View ArticleSenator Targets Carried Interests
Wednesday, Senator Al Franken sent a letter to the Department of Treasury taking aim at “carried interest” income. In the letter, Senator Franken asked the IRS to revise Form 1065 (the tax return form...
View ArticleCarried Interests – Here We Go Again
Following up on last week’s blog post on carried interests, a new bill was introduced Friday in the House of Representatives targeting carried interests. This bill, H.R. 2889, is titled the Carried...
View ArticleHouse Expected to Tie Infrastructure and Tax Reform Together
In a July 2nd statement, the House Ways and Means Committee indicated that they intend to tie much needed highway funding to their goal of tax reform. Particularly, corporate tax reform. It is unclear...
View ArticleHalving the Built-in Gain Period?
Following up on my February post discussing a proposal to reduce the built-in gain period for S corporations, this proposal is one step closer to becoming a reality. The S Corporation Modernization Act...
View ArticleClinton to Propose Higher Capital Gains Rates
Hillary Clinton is expected to propose later this week a revamping of capital gains rates. While the specifics are not yet released, Clinton’s proposal is expected to increase the current maximum...
View ArticleRevamping U.S. Taxation of Multinational Corporations?
The Obama administration and top lawmakers are in discussions regarding a potential overhaul of how the United States taxes U.S. multinational corporations. Topics under consideration include...
View ArticleClinton Outlines Her Capital Gains Rate Hike
Following up on my post from last week, presidential candidate Hillary Clinton has now provided more specific information on her proposed capital gains rates hike. For high income filers (couples...
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