The Tax Court has concluded that a taxpayer wasn't entitled to a foreign earned income exclusion under Code Sec. 911(a) for the tax year at issue, because he failed to make a timely election under Reg. § 1.911-7(a)(2)(i), which provides that if the taxpayer is filing a late return and owes income tax after taking…
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Third-Party Summons Rules Applies To Data on Taxpayer's Marijuana Business
The district court has made several rulings regarding Code Sec. 280E, the Code section that disallows deductions in carrying on a trade or business that consists of trafficking in controlled substances. One such ruling was that Code Sec. 7609(c)(2)(E)(i), which provides an exception to the Code's third-party summons rules where the summons is issued by…
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New Limits on Regs Trump New 385 Regs!
On November 16, 2016 we posted Treasury Issues Final & Temporary Section 385 Regs - But May Not Last Under President Trump? where we discussed that the Obama administration’s announcement of a crackdown on inversions the U.S. Treasury issued final & temporary proposed regulations that would dramatically change the taxation of corporate debt issued to related corporations…
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IRS Rescinds Termination of Foreign Certified Acceptance Agents
IRS has recently notified foreign CAAs by email that, effective Apr. 17, 2017, IRS has rescinded the termination letter that they had previously been sent. In the email, IRS stated that if a CAA's Certified Acceptance Agent Agreement was not set to expire on Dec. 31, 2016, then no further action was required on their…
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