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The article focuses on the U.S. Internal Revenue Service (IRS's) proposed regulations under Sec. 166, which aim to broaden bad debt conformity for regulated financial entities. Topics include: the introduction of a new allowance charge-off method that expands eligibility beyond current methods; the elimination of outdated safe harbors and requirements for express determination letters; and the procedural changes for adopting the new method, which may benefit regulated entities.

The article delves into the intricacies encountered by tax professionals when navigating whether to capitalize or expense expenses linked to tangible property. It sheds light on two significant safe harbors: the de minimis safe harbor and the safe harbor for routine maintenance. It is reported that these provisions offer clarity amidst the subjective nature of such determinations, providing taxpayers with avenues to streamline their tax treatment of tangible property expenses.

The article focuses on common improvement costs in real property basis and taxpayer's adjusted basis in property for purposes of determining gain or loss from the property's sale. It mentions property is adjusted for any expenditure properly chargeable to a capital account and real estate developers often are required by law to develop common improvements. It also mentions developer of real estate to obtain IRS consent to use an alternative cost method (ACM) as a safe harbor.

The article reports that U.S. Internal Revenue Service (IRS) issued a revenue procedure on October 1, 2019 on U.S. persons who own stock in controlled foreign corporations (CFCs) may be able to benefit from safe harbors for determining CFC status and resulting income inclusions. It mentions foreign corporation owned by a foreign person can be attributed to a U.S. person under the downward attributions rules.

The article reports that U.S. Internal Revenue Service (IRS) has issued proposed regulations on the items of income and deductions that are included in calculating built-in gains and losses. It mentions regulations reflecting changes made to the Internal Revenue Code by the law known as the Tax Cuts and Jobs Act (TCJA). It also mentions proposed regulations would eliminate the so-called 338 approach, a safe-harbor method as set forth in Notice 2003-65.

The article informs on a guidance on Section 199A regulations issued by the U.S. Internal Revenue Service, on how to treat previously suspended losses and how to determine the deduction for taxpayers that hold interests in regulated investment companies, charitable remainder trusts, and split-interest trusts. It informs that the notice provides safe-harbor rule for rental real estate businesses and a revenue procedure on calculating W-2 wages.

The article reports that the U.S. Internal Revenue Service (IRS) released guidance on a large number on qualified business income deduction. It mentions how to determine the deduction for taxpayers that hold interests in regulated investment companies (RICs), charitable remainder trusts (CRTs), and split-interest trusts. It also mentions guidance also includes a notice that provides a safe-harbor rule for rental real estate businesses and a revenue procedure on calculating W-2 wages.

The article focuses on the guidance issued by the U.S. Internal Revenue Service (IRS) and issued new proposed regulations on how to treat previously suspended losses and how to determine the deduction for taxpayers that hold interests in regulated investment companies (RICs), charitable remainder trusts (CRTs), and split-interest trusts. It also mentions guidance also includes a notice that provides a safe-harbor rule for rental real estate businesses and a revenue procedure.

The article offers information on laws governing net unrealized built-in gain and net unrealized built-in loss safe harbors under Section 382 of U.S. Tax Cuts and Jobs Act. Topics discussed include preventing taxpayers from trafficking in tax attributes; prevention of use of net operating-loss carryforwards and certain built-in losses; and income tax deductions for the same.

The article provides potential strategies for minimizing estimated tax payments. Topics discussed include prevention of tax underpayment penalties; minimizing quarterly payments by alternating safe-harbor exceptions; and allocating income from passthrough entities for avoiding the same, along with withholding individual retirement account distribution.

The article focuses on the revenue procedure by the U.S. Internal Revenue Service (IRS) which provides a safe harbor for accrual basis taxpayer to treat economic performance with several types of service contracts. It mentions that revenue procedure provides several types of services that could qualify under the safe harbor including janitorial services, landscape maintenance services, and information technology.

The article reports that American Institute of Certified Public Accountants (AICPA) has requested last-in, first-out (LIFO) inventory that experiences a decrease in LIFO inventory. It mentions LIFO decrement is the excess of the prior-period ending inventory over the current-period ending inventory. It also mentions government restrictions implemented in response to the COVID-19 pandemic severely limited manufacturing capacity and caused interruptions in foreign trade and global supply chain.

The article reports that the U.S. Internal Revenue Service (IRS) has issued a safe harbor that allows an employer to exclude certain amounts received from other coronavirus economic relief programs in determining whether it qualifies for the employee retention credit (ERC) based on a decline in gross receipts. It mentions forgiveness of Paycheck Protection Program (PPP) loans and Restaurant Revitalization Fund (RRF) grants under the American Rescue Plan Act.

The article discusses that the IRS announced a safe harbor for certain businesses that received first-draw Paycheck Protection Program loans but did not deduct eligible expenses as the guidance was issued before the enactment of the Consolidated Appropriations Act, 2021. The safe harbor in Rev. Proc. 2021-20 allows taxpayers who filed a tax year 2020 return on or before Dec. 27, 2020, to deduct the expenses on next tax return.

The article focuses on the U.S. Internal Revenue Service's (IRS) tangible property regulations and how they impact taxpayers in the petroleum industry. Topics include the unit-of-property determination, the special rules regarding paid tax amounts, and safe harbor election limit. Information is provided on de minimis elections for petroleum companies.

The article focuses on the issuance of liquidation value safe harbor provisions by the U.S. Internal Revenue Service (IRS). Topics include the IRS' definition of liquidation value, bad debt deductions for creditors, and the transfer of creditor positions in debtor partnerships. Information is provided on cancellation of debt (COD) income.

The article discusses the U.S. Internal Revenue Service's (IRS's) release of temporary regulations regarding the expenditures associated with the acquisition, improvement, and maintenance of tangible property under Sections 162(a), 168, and 263(a) of the nation's Internal Revenue Code. It states that the IRS plans to issue final regulations on the topic in 2013. Revised de minimis rules and safe harbors are also addressed in the IRS regulations.

The article discusses employee benefits and pensions in the U.S. as of November 2012, focusing on various tax-related issues in regards to compensation, retirement plans, and executive compensation. 401(k) plans and the U.S. Internal Revenue Service's Listing of Required Modifications (LRM) are addressed, along with the nation's Small Business Jobs Act of 2010. Section 402(g) of the U.S. Internal Revenue Code and safe-harbor matching contributions are examined.

The article focuses on the classification of office artwork as depreciable property under U.S. internal revenue law. Topics include the valuation of artwork or memorabilia, safe harbor provisions applied to artwork valuation, and the depreciation of tangible personal property. Information is provided on the U.S. Economic Recovery Tax Act (ERTA).

The article examines the laws defined under the U.S. Internal Revenue Code's Section 704(b) that provide a safe harbor under which the U.S. Internal Revenue Service (IRS) will respect a partnership's allocations as having economic effect. It reports that requirements of the safe harbor are that the partnership must maintain the partners' capital accounts in accordance with the Sec. 704(b) capital accounting rules.

The article presents several question and answers regarding the revenue procedure of the U.S. Internal Revenue Service (IRS) which provides certain retailers and restaurants a safe-harbor method of accounting for remodel or refresh expenditures on qualified buildings.

The article focuses on tangible property regulations provide a potential opportunity to continue depreciating a building after demolition has occurred which include the building in a General Asset Account (GAA). It mentions that tax preparers to identify on the lose of all future tax depreciation deductions and the U.S. Internal Revenue Service (IRS) provided a safe harbor for purposes of determining whether structural modifications to a building are considered a demolition.

• A theft loss incurred in an activity engaged in for profit is deductible as a miscellaneous itemized deduction not subject to the 2% of adjusted gross income floor. Whether or not a theft loss has occurred is determined under the law of the state where the loss occurred. • Generally, for an investment loss to be a theft loss, the party perpetrating the fraud must have had a specific intent to defraud the victim and the victim must have purchased the investment directly from the perpetrator. • A theft loss for which there is no prospect of recovery is deductible in the year the theft is discovered; however, if there is a reasonable prospect of recovery, the loss is not deductible until it is determined with reasonable certainty whether a reimbursement will be received. • Losses from Ponzi schemes will generally be treated as theft losses; under Rev. Proc. 2009-20, if specific safe-harbor requirements are met, an investor with a loss from a Ponzi scheme may deduct a specified percentage of the loss as a theft loss in the year the theft is discovered. [ABSTRACT FROM PUBLISHER]

• Under the substantially equal periodic payment exception, the account owner must withdraw a substantially equal amount from an IRA annually for five years or until the taxpayer reaches age 59 1/2. The amount that must be withdrawn is based on the taxpayer's life expectancy. • Three safe-harbor methods are available for calculating the annual withdrawal amount: (1) the required minimum distribution method, (2) the fixed amortization method, and (3) the fixed annuitization method. Each method produces a different annual withdrawal amount. • The IRS has been willing to approve taxpayers' requests to use reasonable variations on the safe-harbor methods to calculate their annual withdrawal amounts. • Modification or termination of the SEPP before the end of the required time period results in a retroactive application of the 10% penalty to all previous withdrawals and interest charges from the date each withdrawal was received until the modification or termination occurred. [ABSTRACT FROM PUBLISHER]

The article reports that U.S. Internal Revenue Service (IRS) has extended some deadlines for investing in qualified opportunity funds (QOF) and relaxed some investment requirements to make it easier for QOF investors to deal with the coronavirus pandemic. It mentions working capital safe harbor provides QOZBs with a safe harbor for treating an amount of working capital. It also mentions QOFs that received distributions of QOF stock.

The article reports that U.S. Internal Revenue Service (IRS) has extended its safe-harbor relief from recognizing cancellation-of-debt (COD) income for students whose loans were discharged either because their schools were closed or as a result of some type of fraud. It mentions loans were discharged under a settlement of a legal cause of action resolving various allegations of unlawful business practices, including unfair, deceptive, and abusive acts and practices.

Examines the basic allocation rules in foreign income tax among partners and details the temporary regulations' safe harbor in the U.S. Factors that determine the economic effect of an allocation in a partnership agreement; Allocation of foreign income tax under the safe harbor; Cases that illustrate the safe harbor rules.

Focuses on the revised provision released by the United States Internal Revenue Service (IRS) which provides a safe-harbor structure to property owners. Explanations on the provision of Section 1031 of the Internal Revenue Code regarding property; Judicial and IRS interpretations of the application of Section 1031 to reverse exchanges; Details on pre-safe-harbor transactional issues.

The article reports that the U.S. Internal Revenue Service has issued the Revenue Procedure (Rev. Proc.) 2015-12 rule to provide guidance and safe-harbor methods of accounting for cable system operators which offers video, high-speed internet, and voice-over-internet protocol (VoIP) phone services through cable network. It also mentions that the cable operators may file an automatic request for a change in method of accounting.

The article focuses on the U.S. Internal Revenue Service's (IRS) safe harbor deduction for investment advisory milestone payments. Topics include the deduction of financial advisory fees, the deduction of business-related costs, and success-based fee deductions. Information is provided on the capitalization of success fees.

The article focuses on the rules governing convertible debt and stock warrants in the U.S. in 2014. Topics include the net operating loss (NOL) of corporations, the differences between common stock and preferred stock, and the safe-harbor options governing stock transfers. Information is provided on stock purchase agreements.

The article focuses on the de minimis safe harbor election under the U.S. Internal Revenue Service's (IRS) tangible property regulations. Topics include the deduction of costs under the de minimis regulations, the written capitalization procedures, and the review of financial statements. Information is provided on the generally accepted accounting principles (GAAP) accepted by the IRS.

The article reports that U.S. Internal Revenue Service (IRS) provided a safe-harbor procedure for taxpayers under which a rental real estate enterprise will be treated as a trade or business for the qualified business income (QBI) deduction of Section 199A. It mentions property leased under a triple net lease or used by the taxpayer including an owner or beneficiary of a relevant passthrough entity (RPE). It also mentions need of reviewing financial statements or reports on operations.

The article focuses on the treatment of safe harbor for professional sports teams trading personnel contracts and draft picks under the U.S. Tax Cuts and Jobs Act. Topics discussed include tax treatment of trading contracts or draft picks between teams; the treatment of Internal Revenue Service on same; and team's financial statements must not reflect assets or liabilities resulting from the trade other than cash for the purpose of safe harbour.

The article focuses on nonaccrual-experience (NAE) in safe harbor method qualifications. Topics include the classification of uncollectible revenue, the gross receipts test, and the penalties in place for compliance failures. Information is provided on qualified service and annual receivable determinations.

The article focuses on the the calculation of golden parachute compensation packages and the rules governing these bonuses. Topics include the discouragement of excessive compensation, safe harbor provisions, and the loss of tax deductions for companies that award executives excess parachute payments.

The article offers information about regulation Rev. Proc. 2011-46 issued by the U.S. Internal Revenue Service (IRS) related to safe harbor for nonaccrual-experience (NAE) accounting method taxpayers. Topics include Regs. Sec. 1.448-2 under internal revenue law, the change for doubtful accounts under the regulation, and the change to create a safe harbor provision for NAE.

The article focuses on a new mark-to-market valuation safe harbor offered by the U.S. Internal Revenue Service (IRS) in 2011. The IRS has ordered examining agents to provide a safe-harbor election to taxpayers being examined for the market values used in calculations under Section 475 of the Internal Revenue Code. Fair market values (FMVs) of applicable securities are used in the calculations. It stresses the need to modify the language used in certification statement disclosures.

The article offers information on guidance on losses from Ponzi schemes issued by the U.S. Internal Revenue Service (IRS) in 2009. A safe-harbor method for making a taxpayer's determination of the amount of losses from the scheme and the year in which they should be deducted was also provided by the IRS in Revenue Procedure 2009-20. General application of the new guidance to specified fraudulent arrangements, being defined by the agency as an arrangement in which a party receives cash or property from investors, is discussed.

The article focuses on a provision of the tax law in the U.S., known as the transfer-for-value rule. It states that the transfer-for-value rule under Section 101(a)(2) is one of the most important and challenging areas that the tax adviser must properly address to clients when dealing with life insurance transactions. Accordingly, any one of the safe-harbor exceptions to the rule can effectively serve to insulate a policy's death proceeds from adverse income tax consequences.

Focuses on the clarification made by the U.S. Internal Revenue Service (IRS) regarding innocent spouse equitable relief. Information on the Request for Innocent Spouse Relief And Separation of Liability and Equitable Relief; Guidance on equitable relief from the underpayment of tax liabilities provided by the Revised Proclamation 2003-61; Threshold conditions for the requesting spouse; Safe-harbor circumstances to be considered by the IRS for the provision of Section 6015(f) equitable relief.

The article offers insight to the guidelines issued by the U.S. Internal Revenue Service Large Business and International Division focusing on new safe-harbor method for calculating qualifying research expenditures (QRE) by taxpayers. Topics discussed include use of research and development (R&D) costs as the starting point for computing QREs; R&D costs as calculated on their certified audited financial statements; and its impact on taxpayers.

The article discusess the role of employer in checking that the health savings accounts does not accompany Employee Retirement Income Security Act (ERISA) in the U.S. Topics discussed include two safe harbors provided by the U.S. Department of Labor for helping employers to avoid ERISA; maximization of the tax savings by employees; and use of group-type insurance programs for avoiding the same.

The article offers information on a notice issued by U.S. Internal Revenue Service related to de minimis safe harbor from information returns. Topics discussed include payee statements for not requiring safe harbor; and manner of making an election of avoiding safe harbor such as writing, online, or telephone.

The article informs on guidance issued by the U.S. Internal Revenue Service under which sports teams that trade player contracts or draft picks will be able to treat the contracts and draft picks as having a zero value for determining gain or loss to be recognized on the trade under a safe harbor.

The article informs on Notice 2019-07 issued by the U.S. Internal Revenue Service which provides a revenue procedure that would provide a safe harbor for taxpayers under which a rental real estate enterprise will be treated as a trade or business for purposes of the Sec. 199A deduction. It informs that under the safe harbor rental real estate enterprise would be treated as a trade or business for purposes of Section 199A; and a rental real estate enterprise may consist of multiple properties.

The article reports that U.S. Internal Revenue Service (IRS) has issued Notice 2016-36 to provide guidance on new safe harbor rules in which certain property transfers by an energy generating or energy storage facility to a regulated public utility will not be treated as income to the utility company. It mentions that Congress passed the Public Utility Regulatory Policies Act mandated that regulated public utilities must interconnect with qualifying small power producers.

The article informs that the U.S. Internal Revenue Service (IRS) has issued Chief Counsel Advice (CCA) 201624021, as of September 2016. It reports that in CCA the IRS has outlined its position regarding the ability of a target in a Section 338(h)(10) of the U.S. Internal Revenue Code transaction to use the safe harbor election provided by Revenue Procedure 2011-29.

The article focuses on the regulations issued by U.S. Internal Revenue Service (IRS) which amend an existing safe harbor that is used for determining whether allocations of creditable foreign tax expenditures (CFTEs). It mentions that CFTEs do not have substantial economic effect in accordance with the partners' interests in the partnership. It also mentions that special rules relating to deductible allocations and nondeductible guaranteed payments.