2018 Waivers of 911 Eligibility Requirements Due to Adverse Conditions

Wednesday, July 3, 2019

The IRS has provided a waiver for any individual who, for the 2018 tax year, failed to meet the eligibility requirements of Code Sec. 911(d)(1) due to war, civil unrest, or similar adverse conditions in certain foreign countries. Qualified individuals may exempt from taxation their foreign earned income and housing cost amounts. An individual who left the […]

IRS Clarifies Treatment of Refunds with New SALT Limits

Wednesday, July 3, 2019

The IRS has provided four examples of the interaction of the new limit on the deduction on state and local taxes (SALT) under Code Sec. 164(b)(6) with the tax benefit rule for refunds under Code Sec. 111. A taxpayer who is impacted by the SALT limit may not be required to include any refund in gross income depending […]

IRS Allowed to Treat Partnership as Aggregate of its Partners

Wednesday, July 3, 2019

The IRS was allowed to assert its authority under the abuse of entity rule of Reg. §1.701-2(e) to treat a partnership as an aggregate of its partners. Treating the partnership as an aggregate was appropriate for purposes of Code Sec. 367(d). Under Code Sec. 367(d) and its regulations, a U.S. person that transfers intangible property to a foreign corporation in […]

2019 Foreign Housing Expense Limitations Released

Wednesday, July 3, 2019

The IRS has provided the adjustments to the limitation on foreign housing expenses for specific locations for tax year 2019. Generally, a qualified individual whose entire tax year is within the applicable period is limited to maximum housing expenses of $31,770 for 2019. Similarly, the computation of the base housing amount is also tied to […]

IRS Issues 2018 Nonconventional Source Fuel Reference Price

Wednesday, July 3, 2019

The IRS has published the nonconventional source fuel reference price for calendar year 2018. The credit period for the nonconventional source production credit under Code Sec. 45K ended on December 31, 2013, for facilities producing coke or coke gas (other than from petroleum based products). However, the reference price continues to apply in determining the amount of […]