IRS: Foreign Corporation Holdings

December 20, 2019By Smeriglio Associates LLCNews

The IRS is granting relief to U.S. persons who own stock in certain foreign corporations. Revenue Procedure 2019-40 limits the inquiries required by U.S. persons to determine if certain foreign corporations are controlled foreign corporations (CFCs). It also allows certain unrelated minority U.S. shareholders to rely on specified financial statement information to calculate their subpart … Read More

U.S. Tax Court: Filing Tax Return From Jail

December 19, 2019By Smeriglio Associates LLCNews

The U.S. Tax Court ruled that being in jail doesn’t mean a tax return isn’t due. The taxpayer was a former pro basketball player who was convicted of wire fraud. While incarcerated, he received a $208,111 pension distribution. He didn’t file a return for the distribution year, so the IRS prepared a “substitute return” and … Read More

U.S. Tax Court: Premium Tax Credit

December 18, 2019By Smeriglio Associates LLCNews

A premium tax credit (PTC) subsidizes the cost of health insurance purchased by taxpayers through a Health Insurance Marketplace. It’s available to those with household incomes between 100% and 400% of the federal poverty line. In one case, a husband published his sister’s cause-related book but had stopped promoting it by the tax year in … Read More

U.S. District Court: State and Local Tax Cap

December 17, 2019By Smeriglio Associates LLCNews

A U.S. District Court has dismissed four states’ constitutional challenge to the state and local tax (SALT) cap enacted as part of the Tax Cuts and Jobs Act. The court found that the states had failed to plausibly allege that the SALT cap impaired their ability to pursue their own preferred tax policies. Therefore, the … Read More

Bridging the gap between budgeting and risk management

December 16, 2019By Smeriglio Associates LLCNews

At many companies, a wide gap exists between the budgeting process and risk management. Failing to consider major threats could leave you vulnerable to high-impact hits to your budget if one or more of these dangers materialize. Here are some common types of risks to research, assess and incorporate into adjustments to next year’s budget: … Read More

IRS: S Corporation Revocation Deadline

December 16, 2019By Smeriglio Associates LLCNews

The rules that allow certain benefits to S corporations that revoke their S corporation status and become C corporations (referred to as eligible terminated S corporations, or ETSCs) are applicable only if the revocation takes place by Dec. 21, 2019. An ETSC is a C corporation that was an S corporation on Dec. 21, 2017, … Read More