Section 1.163(j)-1: Common definitions used throughout the Final Regulations Treas. Reg. Section 1.163(j)-1 contains definitions used throughout the Final Regulations. Significant modifications to the 2018 Proposed Regulations include: 1. Definition of ATI...
Proposed Regulations Released on IRC Section 199A Pass-Through DeductionPeter J. UlrichTodd M. Kellert
Reg. Section 1.704-1(b)(2)(iv)(f). Where such transactions occur in a tiered partnership context, the Regulations require a UTP to look through the tiers of entities to any capital assets held in lower-tier partnerships (LTPs) —...
tax determined under section 6411(b) is otherwise prevented by the operation of any law or rule of law other than section 7122, such application, credit, or refund may be allowed or made if application for a tentative carryback adjustment is made within the period provided in section 6411(a...
Proposed Regulations Clarify the IRC Section 199A DeductionDalton, Thomas M.CPA Journal
Internal Revenue Service (IRS). It mentions that the NPRM is aimed to clarify the boundaries of "social welfare organizations" under Section 501 of the Internal Revenue Code (IRC).International Journal of Not-for-Profit LawGorovitzPrincipalEricPrincipal...
New Proposed Regulations Issued Under IRC Section 409ARandall C. McGeorge
Condition when a gain attributable to the unrecaptured IRC section 1250 gain is recognized; Determining the amount of unrecaptured IRC section 1250 gain; Examples under Treasury Regulations.BlumenthalStevenMorrisEdwinB.TipographNeilIpKamcheungT.
New Proposed Regulations Clarify and Add Flexibility to IRC Section 409A RegulationsSchneider, Paul J.
Prop. regs. on sec. 6045(f) attorney reporting.(IRS regulations; IRC section 6045(f))Pflieger, Deborah JFox, George