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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About: Ronald Marini
Recent Posts by Ronald Marini
IRS Update Makes Voluntary Disclosures For ALL Domestic & Foreign Disclosures More Expensive
The cost of ALL Voluntary Disclosures of previously unreported income or offshore assets to the IRS avoid criminal prosecution, just got more expenses under an updated procedures the revenue agency released on November 29, 2018. IRS deputy commissioner for services and enforcement Kirsten Wielobob issued a memorandum on November 20, 2018 that the IRS posted publicly Thursday,…
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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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