Because
Sec. 199 results in a deduction for qualifying taxpayers, questions began to arise shortly after the section's enactment that relate to the interplay of the deduction with other Code provisions.
Under
Sec. 419(c)(3), a benefit's qualified direct cost in any year is that year's cost of providing the benefit, plus related administrative costs, based on the cash method of accounting.
* The IRS is studying the current
Sec. 751(b) regulations and considering alternative approaches to achieve
Sec.
Pursuant to
Sec. 645, if both the executor (if any) of an estate and the trustee of a qualified revocable trust so elect, the "electing" trust--a qualified revocable trust (QRT) that makes the
Sec.
The TIPRA made significant changes to the
Sec. 355 spinoff rules.
We suggest two ways to help IRC
Secs. 1202 and 1045-related issues result in positive client interactions.
* The Service issued additional guidance on the interpretation of plans under
Sec. 355(e) and elections under new
Sec.
In the past year, Treasury issued final regulations (4) on a partnership's obligation to withhold tax on effectively connected taxable income allocable to a foreign partner under
Sec. 1446.
The Tax Court held that TLC was subject to the
Sec. 274(n) limit on per-diem meal expense allowances it paid to the drivers, because it was the driver's common-law employer (see Transport Labor Contract /Leasing, Inc., 123 TC 154 (2004)).
Sec 199 provides a deduction equal to 3% (increasing to 6% for 2007, 2008 and 2009 and then to 9% for 2010 and there after) of the lesser of qualified production activities income (QPAI) or taxable income.
This two-part article offers guidance on
Sec. 66 relief for married clients who are separated and reside in community property states.
In most transactions, the amount of ordinary income recognized under
Sec. 1245 for an item of property equals the lesser of the gain on the particular item of
Sec.