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Code Section 754: Allocating Gain Where it Belongs

Our Recommended Reading List on Tax Policy

Nothing to Fear but Fear Itself: Planning in the Current Environment
Final Subpart F Regulations and Domestic Partnership Tax Reporting
A Year in Review and an Outlook on the Horizon for Tax-Exempt Entities

Latest Articles

  • Connecticut’s Response to the Tax Cuts and Jobs Act of 2017 (Part II)

    By:
    Louis B. Schatz, Esq.
    |
    Mar 1, 2019

    This article is the second in a two-part series about Connecticut’s Response to the Tax Cuts and Jobs Act of 2017 (the “New Federal Tax Act”). To read the first part published in the February 2019 TaxStringer, which summarized the provisions of Connecticut’s new pass-through entity tax, please click here.  This second part of the series summarizes the remaining significant provisions of the new Connecticut legislation that was adopted in response to the New Federal Tax Act.

  • New York State Sales Tax Audits

    By:
    Alfred T. Grillo, CPA
    |
    Mar 1, 2019
    Every New York business should be concerned about a potential sales tax audit. The result could be expensive and time consuming, and could also expose the owners of the business to personal financial responsibility. This article will discuss some of the various ways businesses can be selected for audit, and the areas where auditors are likely to focus. Knowing these factors may assist CPAs in limiting audits and liability for their clients.

  • New Jersey Tax Update

    By:
    Chaim Kofinas, CPA
    |
    Mar 1, 2019

    On July 2, 2018, the New Jersey Legislature passed—and Governor Phil Murphy signed—his first budget. This budget was designed to move New Jersey in a new direction as envisioned by the new Governor. The budget bill contains tax increases, tax breaks, and a host of other provisions.

  • Structuring a Transaction: Ways to Minimize Income Tax Implications for Sellers

    By:
    Lisa M. Cribben, CPA/ABV, ASA, CMA and Crystal Christenson, CPA, MST
    |
    Mar 1, 2019

    Most taxable sale transactions are typically structured in one of three ways: asset sale, stock sale, or stock sale with a Sec. 338(h)(10) election. Each of these structures provides certain advantages to the buyer or seller. Below we’ll discuss the nuances of each structure and the importance of the allocation of the sales price. 

  • IRS Issues New Guidance on Section 199A Qualified Business Income Deduction

    By:
    Ed Morris, CPA
    |
    Feb 1, 2019
    On January 18, 2019, in response to many comments regarding last summer’s proposed regulations, the IRS issued final and new proposed regulations concerning the Code Section 199A pass-through deduction. At the same time, the IRS issued a revenue procedure dealing with the calculation of W-2 wages and a welcome proposed revenue procedure providing a safe harbor for rental real estate activities.

  • Practical Sales Tax Considerations for Vendors in the Wake of Wayfair (Part II)

    By:
    Mark Klein, JD and Joe Endres, JD
    |
    Feb 1, 2019
    In last month’s installment, we provided a brief review of the U.S. Supreme Court case South Dakota v. Wayfair, and included a state-by-state review of the new laws and rules governing sales tax administration that the case has engendered. News in this area is exploding on almost a daily basis.  

  • Connecticut’s Response to the Tax Cuts and Jobs Act of 2017 (Part I)

    By:
    Louis B. Schatz, Esq.
    |
    Feb 1, 2019
    The Tax Cuts and Jobs Act of 2017 (TCJA) was signed into law on December 22, 2017. Most of the provisions of the New Federal Tax Act were effective January 1, 2018 (although some provisions went into effect in 2017). The adoption of the New Federal Tax Act had a significant impact on state taxation, especially in states like Connecticut, where the base for the Personal Income Tax starts with federal adjusted gross income. 

  • Looking Under the Hood of Mutual Funds and ETFs

    By:
    David J. Perrotto
    |
    Feb 1, 2019
    Did you know that according to Leichtman Research Group’s annual on-demand study, 54% of U.S. adults said they have Netflix in their household? Why do I mention this? Because it’s the same number of Americans that own individual stock, a stock mutual fund, or participate in a self-directed 401(k) or IRA, and roughly half those assets are outside IRAs. 

  • Fiduciary Income Tax Planning: Income Taxation of Trusts Under the New Tax Act

    By:
    Carl C. Fiore, JD, LLM
    |
    Jan 1, 2019

    The Tax Cuts and Jobs Act of 2017 (TCJA) represents a broad-based change to the U.S. tax code, touching on virtually every area of taxation, including of course fiduciary income tax. While some aspects of the new tax law impact trusts directly, the effect of the TCJA on individuals may have even greater implications for trust planning. 

  • Medtronic v. Commissioner: New Direction for Transfer Pricing Cases?

    By:
    Rita Chung, CPA
    |
    Jan 1, 2019
    For tax years 2005 and 2006, the IRS proposed a transfer pricing adjustment resulting in a tax deficiency of over $1.35 billion.  Medtronic filed a lawsuit in the U.S. Tax Court, and in June of 2016, the Tax Court issued its decision disagreeing with the IRS’s allocation of income.  
Page

Tax Cases


In Case You Missed It – May 2023
Tax Jokes
  

Which Avenger pays the least taxes? Spider-Man, because his income is all net.

https://parade.com/1317763/jessicasager/accounting-jokes/

Tax News


IRS, Other Agencies Issue COVID-19 FAQs in Response to Impending End of Public Health Emergency,The Trusted Professional

Tax Court Rules IRS Does Not Have Statutory Authority to Assess Penalties for Failure to File Form 5471,Forbes Media LLC

IRS Revises Guidance on Bitcoin, in Light of Its Use As Legal Tender in Some Nations,The Trusted Professional

Hight Court Considering Case on Whether IRS Can Secretly Obtain Bank Records of Taxpayer's Relatives,The Trusted Professional

More Foreign Companies Than Expected May Be Subject to 1% Buyback Tax,The Trusted Professional

After Beyoncé Failed to Work It Out With IRS, She Filed A Petition in Tax Court,Forbes Media LLC

*Outside the Box is a new addition to the TaxStringer featuring important articles on financial and investment management topics by top authors who have expertise both inside and outside the realm of taxation.

 

 

Interested in writing for the TaxStringer? Click here for Submission Guidelines and contact TaxStringer@nysscpa.org.


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Views expressed in articles published in Tax Stringer are the authors' only and are not to be attributed to the publication, its editors, the NYSSCPA or FAE, or their directors, officers, or employees, unless expressly so stated. Articles contain information believed by the authors to be accurate, but the publisher, editors and authors are not engaged in redering legal, accounting or other professional services. If specific professional advice or assistance is required, the services of a competent professional should be sought.