Tag Archive for Treasury Department

Treasury Department And IRS Issue Guidance For Consolidated Groups Regarding Net Operating Losses

Treasury Department And IRS Issue Guidance For Consolidated Groups Regarding Net Operating Losses

The Department of the Treasury and the Internal Revenue Service issued proposed regulations and temporary regulations that provide guidance for consolidated groups regarding net operating losses (NOLs).

The Tax Cuts and Jobs Act (TCJA) and the Coronavirus Aid, Relief, and Economic Security Act (CARES Act) amended the rules for NOLs. After amendment, the NOL deduction is the sum of:

The total of the NOLs arising before January 1, 2018 (pre-2018 NOLs) that are carried to that year; plus
The lesser of:
The total of the NOLs arising after December 31, 2017; or
80% of taxable income less pre-2018 NOLs (the 80% limitation).
The TCJA generally eliminated NOL carrybacks and permitted NOLs to be carried forward indefinitely. The TCJA also provides special rules for nonlife insurance companies and farming losses. Nonlife insurance companies are permitted to carry back NOLs two years and forward 20 years, and the 80% limitation does not apply. Farming losses are permitted to be carried back two years and carried forward indefinitely, subject to the 80% limitation.
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Written by | Posted in CARES ACT • NOLs • Tax Cuts and Jobs Act • TaxConnections

IRS Issues Guidance On Business Interest Expense Limitations

IR-2018-82, April 2, 2018

WASHINGTON ― The Treasury Department and the Internal Revenue Service (IRS) yesterday issued Notice 2018-28, which provides guidance for computing the business interest expense limitation under recent tax legislation enacted on Dec. 22, 2017.

In general, newly amended section 163(j) of the Internal Revenue Code imposes a limitation on deductions for business interest incurred by certain large businesses. For most large businesses, business interest expense is limited to any business interest income plus 30 percent of the business’ adjusted taxable income. Read More

Written by | Posted in Business Interest Expense • IRS

Getting To Know The Structure of The IRS

The IRS is an agency of the Treasury Department and is charged with the administration of the tax laws. It is the largest government agency in the world. Headed by the Commissioner of Internal Revenue, its structure is as follows:

(1) There are four civil compliance divisions responsible for serving specific groups of taxpayers with similar needs. They are:

a. Wage and Investment Division: This division services 88 million individual taxpayers who have only wage and investment income, almost all of which is reported to the IRS by third-party payors.

b. Small Business Self-employed Division: This division is responsible for taxpayers who Read More

Written by | Posted in IRS • Treasury Regulations

US Signed 22 FATCA Agreements – Unimpeded By Republicans!

The United States Treasury Department announced February 5, 2014 that Canada and Hungary will implement the Foreign Account Tax Compliance Act (FATCA), in an effort to discourage offshore tax evasion.

The Republican National Committee recently voted to call for the repeal of FATCA and plans to make it a campaign issue this year (see FATCA Implementation Unimpeded by Republicans!)

In an effort to alleviate the concerns of foreign governments about their own bank secrecy laws, the Treasury Department has been negotiating a series of intergovernmental agreements under which it also agrees to share information about their citizens and Read More

Written by | Posted in FATCA

IRS Delays FATCA Registration For Six Months!

Fatca Flag[1]We posted on Wednesday, July 10, 2013 “FACTA Registration is Set To Begin in July!” which discusses that starting on July 15, 2013, the United States is scheduled to begin registering foreign financial firms with U.S. customers for a new anti-tax evasion law know as FATCA. Today the IRS issued Notice 2013-43, which provides Six-Month Extension for FATCA Withholding!  This notice provides a six-month extension for when withholding will begin (i.e., payments after June 30, 2014) and for implementing new account opening procedures as well as related requirements to comply with FATCA.

In the preamble to the final regulations, Treasury and the Internal Revenue Service announced their intent to create a FATCA registration website, which would serve as the primary way for FFIs to interact with the IRS to complete the required registration, agreements, and certifications. The preamble stated that the FATCA registration website would be accessible to FFIs no later than July 15, 2013.

After approval of its registration, each PFFI and registered deemed-compliant FFI would be assigned a global intermediary identification number (GIIN), which would be used both for reporting purposes and to identify the FFI’s status to withholding agents. The preamble provided that the IRS would electronically post the first list of PFFIs and registered deemed-compliant FFIs (IRS FFI List) on December 2, 2013, and would update the list on a monthly basis. To ensure inclusion on the December 2013 IRS FFI List, FFIs would need to register by October 25, 2013.   Read More

Written by | Posted in United States

Obamacare Provisions Postponed – And The IRS Has To Implement

iStock_usa umbrellaXSmallThe requirement that businesses provide their workers with health insurance or face fines – a key provision contained in President Barack Obama’s sweeping health care law – will be delayed by one year the Treasury Department said Tuesday.

The postponement came after business owners expressed concerns about the complexity of the law’s reporting requirements the agency said in its announcement. Under the Affordable Care Act, businesses employing fifty or more full-time workers that don’t provide them health insurance will be penalized.

We recognize that the vast majority of businesses that will need to do this reporting already provide health insurance to their workers, and we want to make sure it is easy for others to do so. We have listened to your feedback. And we are taking action,”

Mark J. Mazur, assistant secretary for tax policy wrote in a post on the website of the Treasury Department, which is tasked with implementing the employer mandate. Mazur said the extra year before the requirement goes into effect will allow the government time to assess ways to simplify the reporting process for businesses. Penalties for firms not providing health coverage to employees will now begin in 2015 – after next year’s congressional elections. Read More

Written by | Posted in Tax Policy • United States