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Section 965 Payments, Filings, Refunds and More Refunds? – New IRS Guidance

On December 12, 2018 the Internal Revenue Service (“IRS”) released a Q&A document that confirms the IRS’s earlier guidance on Internal Revenue Code (“IRC”) Section 965 payments and refunds and provides 2018 guidance on the same[1].  The earlier guidance stated that taxpayers making a Section 965(h) deferral election on a 2017 income tax return could …

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Join Us for FGMK’s 2019 Year-End Tax and Business Planning Webinar

In the wake of the 2017 Tax Cuts and Jobs Act, 2018 has become one of the most challenging tax years in recent memory. Coupled with recent regulatory guidance (related to the Partnership Tax Audit rules) and the Supreme Court decision in the Wayfair case (relating to state sales tax nexus), 2018 presents virtually all …

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Listen to FGMK’s 2018 Year-End Tax and Business Planning Webinar

In the wake of the 2017 Tax Cuts and Jobs Act, 2018 has become one of the most challenging tax years in recent memory. Coupled with recent regulatory guidance (related to the Partnership Tax Audit rules) and the Supreme Court decision in the Wayfair case (relating to state sales tax nexus), 2018 presents virtually all …

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Strategies to Maximize Charitable Giving Under the Tax Cuts and Jobs Act of 2017

Article prepared by Tax Senior Manager Phil Levsky With the Tax Cuts and Jobs Act of 2017 (the “TCJA”) increasing the standard deduction to $24,000 for joint filers and $12,000 for single filers, taxpayers with taxable income under these thresholds will receive a tax benefit for making charitable contributions. This alert discusses three potential strategies …

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Favorable Guidance Afforded Taxpayers Making Substantial Taxable Gifts

The Tax Cuts and Jobs Act enacted in December 2017 provided a profound benefit for those holding large estates; that is, the estate and gift tax exemption increased from $5.49 million per individual in 2017 to $11.18 million in 2018 (increasing to $11.4 million in 2019). Many estate planners have been urging their wealthy clients …

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Listen to FGMK’s 2018 Year-End Tax and Business Planning Webinar

In the wake of the 2017 Tax Cuts and Jobs Act, 2018 has become one of the most challenging tax years in recent memory. Coupled with recent regulatory guidance (related to the Partnership Tax Audit rules) and the Supreme Court decision in the Wayfair case (relating to state sales tax nexus), 2018 presents virtually all …

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New Tax Incentive for Employers Providing Paid Family Medical Leave

The Department of the Treasury (the “Treasury”) and the Internal Revenue Service (the “IRS”) recently released Notice 2018-71 (the “Notice”) which provided guidance on the Family and Medical Leave (“FML”) credit and announced the intention of the Treasury and the IRS to publish proposed regulations under Section 45S. This guidance follows earlier guidance provided by …

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Things to Consider When Analyzing Tax Deferred Exchanges and Cost Segregation Studies After 2017

The TCJA modified Internal Revenue Code (“IRC”) Section 1031 to provide that, for transactions entered into after January 1, 2018, only the exchange of real property held for productive use in a trade or business or for investment will qualify for tax deferred treatment. This is a substantial change in the law, as prior to …

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“Investments in U.S. Property by Controlled Foreign Corporations” after TCJA 2017

On October 31, 2018, the United States Department of the Treasury and the Internal Revenue Service released proposed regulations relating to one type of “deemed distribution” from a controlled foreign corporation (“CFC”). These proposed regulations explain how domestic C-Corporations that are “U.S. Shareholders” of a CFC can reduce their deemed income inclusions from the CFC’s …