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Archive for the Tax Planning Category

Regulations to be Proposed Will Require Employer-Sponsored Group Health Plans to Include In-Patient Hospitalization Services

The IRS has announced that the Department of Health and Human Services (HHS) and the Treasury Department (including the IRS) will soon issue proposed regulations providing that a group health plan does not provide minimum value if it excludes substantial coverage to employees for in-patient hospitalization services…

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HR 4 – Jobs for America Act

HR 4 – Jobs for America Act DIVISION I—WAYS AND MEANS TITLE I—SAVE AMERICAN WORKERS Sec. 101. Short title. Sec. 102. Repeal of 30-hour threshold for classification as full-time employee for purposes of the employer mandate in the Patient Protection and Affordable Care Act and replacement with…

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Extenders Likely to Win Passage in November

Lawmakers are likely to pass tax extender legislation during the lame-duck session of Congress in November and comprehensive tax reform as early as 2015, according to tax experts speaking during webcast sponsored by PricewaterhouseCoopers LLP on October 28. According to Rohit Kumar and Scott McCandless, both principals…

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S. 2260 – Expiring Provisions, Improvement, Reform, and Efficiency (EXPIRE) Act of 2014

Below is the Senate version of the tax extenders bill, the EXPIRE Bill of 2014.  All items listed below have expired or will expire in 2014 that this bill has called to extend two to three more years. TITLE I—PROVISIONS EXPIRING IN 2013 Subtitle A—Individual Tax Extenders…

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Extenders Negotiations Continue with a cold White House Response

Negotiations over the fate of more than 50 tax extenders have continued over the Thanksgiving recess. Leaders in both the House and Senate have been in discussions over whether to extend the popular but temporary tax breaks or to make permanent some of the incentives and eliminate…

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Action Needed to Ensure Tax Compliace with FIRPTA

According to new audit report from the Treasury Inspector General for Tax Administration (TIGTA), current IRS procedures are insufficient to ensure that all foreign seller real estate transactions subject to the Foreign Investment in Real Property Tax Act of 1980 (FIRPTA) are in fact compliant with FIRPTA.…

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US Treasury Official Discusses BEPS and Other International Tax Developments

Robert Stack, Treasury deputy assistant secretary (International Tax Affairs), predicts that the department will face a difficult year in 2015 as it begins to tackle several of the tougher issues listed in the Organisation for Economic Co-operation and Development’s (OECD) Base Erosion and Profit Shifting (BEPS) Action…

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Anti-Inversion Proposals Put 42,000 U.S. Jobs at Risk of Going Overseas

Congressional and administrative proposals are failing to address the underlying incentives driving inversions and therefore, putting 42,000 U.S. jobs at risk of going overseas, according to new research from the American Action Forum (AAF), a center-right think tank. The AAF study, released on September 4, also found…

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Court Denies Basis To Partners For Contributions of Notes, But Waives Penalties

The Tax Court has denied basis to individuals who contributed unfunded, unsecured notes to a partnership and claimed basis for the amounts on the notes. As a result, the partners’ bases in their partnership interests were too low for them to claim greater pass-through losses on their…

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Chief Counsel on What Makes Amounts Paid To “Limited Partners” of an LLC Subject To Self-Employment Taxes

IRS Chief Counsel (CCA 201436049) has concluded that so-called limited partners of an investment management firm were not limited partners of the firm (a limited liability company (LLC) treated as a partnership) and were being paid compensation for services. Therefore, the amounts they received from the firm…

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