Treasury Provides Additional Qualified Opportunity Zone Guidance
On April 17, 2019, United States Department of Treasury (“Treasury”) released the highly anticipated second round of proposed regulations pertaining to Qualified Opportunity Zones (the “Proposed Regulations”). While still leaving certain questions open, the Proposed Regulations provide much needed guidance and clarity on a number of major outstanding questions. The Proposed Regulations cover a wide …
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U.S. Residency – Overview and Procedures
The general rule is that only U.S. Persons are subject to tax on their worldwide income on their respective Form 1040. Non-U.S. Persons, in contrast, are only subject to tax on their U.S. source income, and file Form 1040NR. Let us review the distinction and thresholds that determine whether someone is considered a U.S. Person, …
Acceleration Events of the Transition Tax Under IRC Section 965
Taxpayers that elected to pay their 2017 transition tax under IRC Section 965 of the Internal Revenue Code (IRC) in eight installments, and S corporation shareholders that elected to “indefinitely” defer their Section 965 liability, are generally required to pay the remaining balance of the Section 965 tax liability if an acceleration, or triggering, event …
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DOL Proposes Increase to FLSA Overtime Rule Salary Threshold
The U.S. Department of Labor (DOL) published a Notice of Proposed Rulemaking (NPRM) raising the Fair Labor Standards Act (FLSA) salary test threshold to $35,308 per year ($679 per week). This is significantly lower than the $47,476 per year ($913 per week) level proposed by the prior administration in 2016, but represents a significant …
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Retirement Plan Contributions Increased for 2019
Overview of New Limitations Pursuant to IRS Notice 2018-83 (the “Notice”), for the 2019 tax year, the annual contribution limit has increased from $18,500 to $19,000 for employees who participate in an employer sponsored retirement plan under Internal Revenue Code (“IRC”) Sections 401(k) and 403(b), as well as most IRC Section 457 government retirement plans and the …
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Performance Improvement Perspective: Obsolete Inventory
With the passage of Senate Bill 9 on July 7, 2017, Illinois made substantial changes to its treatment of unclaimed property. These changes affect the reporting responsibilities of unclaimed property holders, including the types of property covered by the law. The following is FGMK’s overview of the state of unclaimed property law in Illinois for …
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Governor Pritzker’s Fair Tax for Illinois and Graduated Income Tax Plan
On March 7, 2019, citing Illinois’ dire fiscal condition, Governor J.B. Pritzker unveiled the details of his “Fair Tax for Illinois” plan, commonly referred to as the “Fair Tax.” Governor Pritzker’s proposal highlights four elements: a graduated personal income tax regime; an increase to the corporate income tax rate from 7% to 7.95%; a 20% …
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FGMK Tax Alert: Rental Real Estate Enterprise Safe Harbor
On January 18, 2019, the United States Department of the Treasury (“Treasury”) and the Internal Revenue Service (“IRS”) released several items of additional guidance regarding Section 199A of the Internal Revenue Code (“IRC” or the “Code”). The guidance included Notice 2019-07, which provides a proposed revenue procedure that sets forth a safe harbor under which …
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Understanding the Basics of Illinois’ Treatment of Unclaimed Property
With the passage of Senate Bill 9 on July 7, 2017, Illinois made substantial changes to its treatment of unclaimed property. These changes affect the reporting responsibilities of unclaimed property holders, including the types of property covered by the law. The following is FGMK’s overview of the state of unclaimed property law in Illinois for …
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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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