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November 2019

Tax Extenders Remain Top Contender for Hitching a Ride on Must-Pass Government Funding Bill

“A thumb goes up, a car goes by…” Tax extenders remain a top contender for “hitching a ride” on November’s must-pass government funding bill.

Wolters Kluwer recently sat down with Jennifer Acuña, Principal, Federal Legislative and Regulatory Services, KPMG LLP, in Washington, D.C. to discuss over 30 temporary tax provisions known as “tax extenders,” which have expired or will soon expire […]

IRS Provides Section 199A Safe Harbor for Rental Real Estate

The IRS has issued a revenue procedure with a safe harbor that allows certain interests in rental real estate to be treated as a trade or business for purposes of the Code Sec. 199A qualified business income (QBI) deduction. The safe harbor is intended to lessen taxpayer uncertainty on whether a rental real estate interest qualifies as a trade or […]

Cryptocurrency Guidance, Virtual Currency FAQs Released

The IRS has released cryptocurrency guidance and frequently asked questions (FAQs) on virtual currency. Under the cryptocurrency guidance:

a taxpayer does not have gross income from a “hard fork” of the taxpayer’s cryptocurrency if the taxpayer does not receive units of a new cryptocurrency; anda taxpayer has ordinary income as a result of an “airdrop” of a new cryptocurrency following a […]

SALT Cap Not Unconstitutionally Coercive

A district court has dismissed a lawsuit filed by four states’ against the federal government, ruling that the $10,000 state and local taxes (SALT) federal deduction cap is not unconstitutionally coercive.

In 2018, New York, Connecticut, Maryland, and New Jersey filed suit against the IRS and Treasury alleging that the SALT cap violates the federalism principles that undergird the U.S. Constitution. […]

Final Regs Revert Back to Prior Partnership Disguised Sale Rules

New final regulations that address the allocation of partnership liabilities for disguised sale purposes revert back to prior regulations. Under the final regulations:

a partner’s share of a recourse liability of the partnership equals the partner’s share of the liability under the rules of Code Sec. 752 and the related regulations; anda partner’s share of a nonrecourse liability of the partnership […]

Preceding Year Disaster Loss Election Final Regulations

The IRS has released final regulation on the election to take a loss resulting from a federally declared disaster in the year preceding the disaster. The final regulations adopt proposed regulations substantially without change.

Disaster DefinedThe regulations provide definitions of:

federally declared disaster;federally declared disaster area;disaster loss;disaster year; andpreceding year.

Scope and Effect of ElectionThe election for a disaster loss attributable to a […]

Proposed Regs Address Tax Implications of LIBOR Elimination

Proposed regulations provide guidance on the potential tax consequences of replacing the London interbank offered rates (LIBORs) with a new reference rate in contracts and agreements.

On July 27, 2017, the U.K. Financial Conduct Authority announced that all currency and term variants of the LIBORs may be phased out after 2021. On March 5, 2018, the Alternative Reference Rates Committee (ARRC) […]

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