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Monthly Archives: December 2018

Disregarded Entities Are Not Always Disregarded

Under the check the box rules, entities owned by one person can often be disregarded for federal tax purposes. Such entities are referred to as "disregarded entities."  As time has progressed since the passage of the check the box rules, the IRS has created more and more exceptions to the disregarded treatment. The following is…
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IRS Issues Additional New Tax Transcript Procedures

On August 23, 2018 we posted IRS to Introduce New Tax Transcript as of 9/23/18! where we discussed that the IRS announced in IR-2018-171 that it is moving to better protect taxpayer data, in a new format for individual tax transcripts that will redact personally identifiable information from the Form 1040 series.   Now, in a Fact…
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IRS Issues Rules On Share Sales By Foreign Partners

According to Law360, the U.S. Department of Treasury on December 20, 2018 proposed rules to treat income from the sale of a foreigner's interest in a U.S. partnership as taxable U.S.-sourced income, overturning a U.S. Tax Court decision that mandated the opposite result. Section 864(c)(8) of the Tax Cuts and Jobs Act effectively re-establishes that the sale…
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