By: Amanda Wilson
As discussed earlier this summer, Treasury and the IRS identified as a burdensome regulation the Proposed Regulations under Section 2704 of the Internal Revenue Code, which regulations would severely impact discounts on gifts made to family members. (Our prior discussion can be found here.) Today, Treasury issued a report announcing that it proposes revoking the proposed regulations. This is good news for taxpayers.
By: Amanda Wilson
Last summer, we discussed the IRS’s issuance of new Proposed Regulations under Section 2704 of the Internal Revenue Code, which regulations would severely impact discounts on gifts made to family members. (Our prior discussion can be found here.) Earlier this year, the Trump Administration issued an executive order instructing the Treasury Department to review all significant tax regulations issued after December 31, 2015 and identify any regulations that impose an undue burden on taxpayers. The Treasury Department and IRS have completed this review, and have identified eight burdensome regulations that should be reformed. The good news for taxpayers is that the Proposed Regulations under Section 2704 are on this list.
By: Amanda Wilson
The Foreign Investment in Real Property Tax Act (FIRPTA) subjects foreign sellers to U.S. tax when they sell their interest in real property located in the U.S., including interests in companies that predominately hold real estate. To accomplish this, the purchasers generally are required to withhold 10% of the gross sales price when the seller is foreign. Legislation that was passed at the end of last year (the PATH Act) increases this withholding rate from 10% to 15% effective as of February 16, 2016. If you are purchasing a U.S. real estate interest from a foreign seller, make sure you are aware of this change and adequately withhold. If you fail to do so, you may find yourself liable for the extra withholding.
By: Amanda Wilson
April 15th is usually greeted with dread as tax day. However, April 15th also offers an important tax planning opportunity for partners in partnerships (including limited liability companies that are treated as partnerships for federal income tax purposes). The tax rules allow partners to amend their partnership agreement retroactively to January 1 of the prior year if the amendment is in place by April 15th. If your business has a partnership, this might be a great opportunity for you. You should take a moment to look at how your partnership is allocating taxable income and losses to the partners in 2013 and make changes if a different allocation would work better for your partnership. Act fast, though, because unlike the due date for filing your return, this deadline cannot be extended.
By: Amanda Wilson
On February 20, 2014, Amanda Wilson will be a panelist on Strafford Publication’s webinar “Form 1065 Reporting and Calculations for Partnership Terminations and Transfers of Interest”. For those that are interested, here is a link with more information about this webinar.
