News & Analysis as of

Tax Deductions Internal Revenue Service

House of Representatives Passes the Tax Cuts and Jobs Act (H.R. 1); Senate Finance Committee Approves Modified Version; Comparison...

by Proskauer - Tax Talks on

Yesterday afternoon, the House of Representatives passed the Tax Cuts and Jobs Act (H.R. 1) (the “House bill”). The House bill is identical to the draft bill approved by the House Ways and Means Committee on November 10. Late...more

S Corp. Shareholder To Tax Court: “Here’s Why I Deserve These Loss Deductions”

by Farrell Fritz, P.C. on

A post earlier this year considered the basis-limitation that restricts the ability of S corporation shareholders to deduct their pro rata share of the corporation’s losses. It was observed that, over the years, shareholders...more

House and Senate Tax Reform Proposals Diverge on Energy Provisions

by Holland & Knight LLP on

On November 2, House Republicans introduced H.R. 1, the Tax Cuts and Jobs Act. Senate Republicans followed suit shortly thereafter, releasing their proposal on November 9. The House Ways & Means Committee concluded its markup...more

Updates for Tax-Exempt Organizations from the Senate Markup to the Tax Cuts and Jobs Act

Over the last several days, there have been significant developments relating to the Tax Cuts and Jobs Act, the pending tax reform legislation in Congress. On Thursday, a detailed summary of the Senate Finance Committee’s...more

Tax Reform: Focus on the Sports Industry

by Proskauer - Tax Talks on

Over the last several days, there have been significant developments relating to the Tax Cuts and Jobs Act, the pending tax reform legislation in Congress. On Thursday, a detailed summary of the Senate Finance Committee’s...more

Tax Planning Under the Tax Cuts and Jobs Act: Flow-Throughs Are the Answer to Everything

by Proskauer - Tax Talks on

The tax reform bills introduced in the House of Representatives and the Senate dramatically reduce the corporate tax rate from 35% to 20% and create added incentives for taxpayers to invest capital into U.S. businesses with...more

Here is what you need to know about IRS proposed draft of Form 1040 for 2017

by Foodman CPAs & Advisors on

As a courtesy to Taxpayers, IRS provides an “early release draft” of an IRS tax form. The drafts are not to be used for filing, but are generally released when most changes have been incorporated into the Form. The...more

New Rules for Tax-Exempt Organizations in the Tax Cuts and Jobs Act

House Republican Tax Bill Imposes Excise Tax on Wealthy Private Universities and Excess Compensation of Highly Paid Employees; Subjects State Pension Plans to UBTI Rules - On Thursday, November 2, House Republicans led by...more

Tax Court Disallows Deductions For Payments To Captive Insurance Company

by Carlton Fields on

A husband and wife who paid $1.54 million in premiums to their captive insurance company and $720,000 in premiums to another insurer over two years, almost all of which ended up back in their bank accounts, have had their tax...more

GOP Tax Bill Outlines Significant Changes for Benefits and Compensation

by Ballard Spahr LLP on

The Committee on Ways and Means yesterday released the proposed Republican tax reform bill, titled the "Tax Cuts and Jobs Act." Although the proposed bill makes major changes to individual and corporate tax provisions in many...more

Qualified Disaster Relief Payments: Federal Loans, Charitable Assistance, Etc.

by Moskowitz LLP on

What if I received a Small Business Association (SBA) Disaster Loan for my business or home? How will it affect my taxes? SBA loans are not treated as income and will not affect your taxes.....more

Tax Court Declines to Follow First Circuit Ruling on Mortgage Subordinations & Conservation Easements

by Coblentz Patch Duffy & Bass on

This month, the Tax Court revived a method to defeat conservation deductions with its October 10 opinion published as Palmolive Building Investors LLC et al. v. Commissioner, No. 23444-14; 149 T.C. No. 18 (Oct. 10, 2017),...more

Are Your Business Deductions at Risk of Being Disallowed by the IRS?

by M. Robinson & Company, P.C. on

Small businesses run on tight margins. The last thing a business owner wants is an IRS notice announcing the disallowance any of their business expense deductions. This is particularly the case for sole proprietorships who...more

Can Employees Pay for Cord Blood Storage with an HRA, FSA or HSA?

The blood remaining in the umbilical cord after childbirth contains stems cells which may be used in a variety of medical treatments. Many parents of newborns are seeking to save this “cord blood”, either with the hopes of...more

Takeaways from the Tax Court's First Micro-Captive Insurance Ruling

by Holland & Knight LLP on

• The U.S. Tax Court recently ruled in Avrahami v. Commissioner, the first litigated Tax Court case involving an 831(b) captive insurance company. • The Tax Court held that two of the key factors that define "insurance"...more

Making an Effective (and Tax Deductible) Donation for Disaster Relief

by Moskowitz LLP on

Relief efforts are underway to assist victims of Hurricane Harvey and those affected by the catastrophic flooding in Texas and Louisiana. Many well-meaning Americans are making donations through a variety of organizations....more

Courts Issue Victories To Conservation Easement Donors

by Fox Rothschild LLP on

August brought three wins for taxpayers who donated conservation easements that were challenged by the IRS. In all of the cases, terms of the conservation easement deed document carried the day....more

Client Alert: Avrahami v. Commissioner: An Important Ruling on Microcaptive Structures

While many were captivated by the solar eclipse on August 21st, the US Tax Court, in Avrahami v. Commissioner, shed judicial light on the tax treatment of what is known as a “microcaptive” insurance company. More...more

New Cases Provide Mixed Messages to Conservation Easement Donors

Fifth Circuit encourages flexibility for conservation easement deductions in Bosque Mountain Ranch, while Tax Court makes it difficult for farmers in Rutkoske. Two important conservation easement opinions were handed down...more

Failure to Disclose Adjusted Basis on Disclosure Form Costs Taxpayer $33M+ Charitable Deduction

by Charles (Chuck) Rubin on

Under Treas. Regs. §1.170A-13, taxpayers making substantial noncash charitable contributions are required to disclose information regarding the contribution on Form 8283. ...more

Seismic Expenses are Deductible for the Seismic Shooter

by Gray Reed & McGraw on

Benjamin Franklin would be relieved. Just when it seems that the taxman always wins, he doesn’t. In CGG Americas, Inc. v. Commissioner the U. S. Tax Court concluded that a taxpayer need not own underlying hydrocarbons in...more

SCORE! for the Boston Bruins – Jacobs v. Commissioner

Like Napolean recognizing that an army marches on its stomach, the owners of the Boston Bruins know a hockey team needs to be well-fed to ensure optimal performance on game day. So, when the Bruins go on the road to play...more

Related-Party Provisions Prevent Deduction by S Corp Shareholders - Tax Update Volume 2017, Issue 4

by Pepper Hamilton LLP on

Many routine transactions occur between related parties, including the payment or accrual of interest on indebtedness, license fees, salary or benefits to employees and/or shareholders, and trade invoices. The Tax Court...more

Meals and Entertainment Expenses Can Be 100% Deductible

In general, a taxpayer may deduct only 50% of its business-related meals and entertainment expenses. This is commonly known as the 50% limit on meals and entertainment expenses. The 50% limit typically applies to the...more

IRS Identifies 8 Burdensome Regulations for Reform

Responding to a Trump Executive Order, the Treasury Department has reviewed all significant tax regulations issued after December 31, 2015 and identified eight regulations to be reformed to mitigate the burden that the...more

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