SCACPA's Weekly Federal Tax Update

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**SCACPA’s Weekly Federal Tax Update**

Lynn Nichols has been explaining federal tax law to audiences since 1969. He is now partnering with SCACPA to launch a series of podcasts that answer questions stemming from the Tax Cuts and Jobs Act. He’ll describe in each installment how the actions of the IRS and the U.S. Tax Court affect how you should interpret the tax code. Listen to each new episode, and you’ll better understand how the new tax laws work.

Latest Episodes:

Federal Tax Update with Lynn Nichols #39 May 03, 2019

Show notes

Lynn Nichols Federal Tax Update Podcast

May, 03 2019, Episode 39

Listen as Lynn Nichols provides commentary on 4 Items pertaining to current developments in U.S. tax law.

IRS Official: Good Recordkeeping Protects Against Bad Clients

Documentation can save practitioners whose clients ignore their advice and apply for tax-exempt status, even when they know they don't qualify, according to an IRS Office of Professional Responsibility official.

[Tax Notes Today; 4/29/2019, Article by Kristen Parillo]

IRS Grants Tax Exemption to Massachusetts-Based Satanic Temple

The Satanic Temple, a self-described nontheistic religious satanic organization based in Massachusetts, has been recognized as a church and granted tax-exempt status by the IRS.

[Tax Notes Today; 4/29/2019, Article by Paige Jones]

Tenth Circuit Affirms Liability for Penalty for Overvaluing Easement

The Tenth Circuit affirmed a Tax Court decision that held a couple liable for a gross valuation misstatement penalty for overstating the value of a conservation easement donation and that held they weren't entitled to deductions under section 1341 for the repayment of proceeds they received for the sale of state tax credits.

[John L. Roth; CA 10, No. 18-9006, 4/29/2019]

Collection Action Sustained Against Food, Wine Festival Operator

The Tax Court held that an IRS settlement officer didn't abuse her discretion in rejecting a hospitality management company's proposed installment agreement and sustaining the proposed collection action for $1.4 million in tax liabilities, finding that the company wasn't in compliance with its current employment tax deposit obligations.

[Coastal Luxury Management Inc.; No. 24206-16L; T.C. Memo. 2019-43, 4/29/2019]

Extended notes coming soon.

Federal Tax Update with Lynn Nichols #38 Apr 26, 2019

Show notes

Lynn Nichols Federal Tax Update Podcast

April, 26 2019, Episode 38

Listen as Lynn Nichols provides commentary on 4 Items pertaining to current developments in U.S. tax law.

2 Percent S Corp Shareholder May Deduct Insurance Premiums

In a legal memorandum, the IRS concluded that an individual who is a 2 percent shareholder of an S corporation under the attribution of ownership rules is entitled to the section 162(l) deduction for amounts paid by the S corporation under a group health plan for all employees and included in the individual's gross income, if some requirements are met.

[ILM 201912001; 12/21/2018, rel. 3/22/2019]

Man May Deduct Some Litigation Costs for Suits Against Ex-Wife

A man suing his ex-wife over various debts can deduct some of those legal fees because the underlying claims involved investment opportunities, according to the Tax Court.

[Tax Notes Today; 4/16/2019, Article by Nathan Richman]

Individual May Deduct Some Legal Fees After Suing Former Spouse

The Tax Court, sustaining penalties, held that an individual can't deduct legal fees under section 162 stemming from lawsuits against his former spouse but some are deductible under section 212, finding that he wasn't engaged in a trade or business from which he claims the expenses originated but that he did engage in the purported business with the intent of generating a profit.

[Ames D. Ray; No. 14052-16; T.C. Memo. 2019-36, 4/15/2019]

Flour Milling Company Denied Increased Research Activity Credit

A company in the business of milling and selling wheat flour was not eligible for section 41 increased research activity credits because no projects met all the requirements to constitute qualified research; however, the company had relied in good faith on its accountants' advice and was not liable for accuracy-related penalties under section 6662.

[Siemer Milling Company; No. 21655-15; T.C. Memo. 2019-37, 4/15/2019]

Ninth Circuit Holds Regs Valid, Nixing Mailbox Rule

Taxpayers can't rely on the common law mailbox rule to prove the timely filing of a refund claim, according to a circuit court decision.

[Tax Notes Today; 4/17/2019, Article by Emily Foster]

[Ninth Circuit Favors Regs Over Mailbox Rule as Refund Suit Heads for Dismissal

The Ninth Circuit, reversing and remanding a refund case for dismissal, held that a lower court erroneously applied the common-law mailbox rule to conclude that a couple's amended return had been timely filed, finding instead that section 7502 and its regulations provide the exclusive means to prove delivery of a tax return to the IRS.

[Howard L. Baldwin et ux.; CA9, No. 17-55115; No. 17-5535]

Federal Tax Update with Lynn Nichols #37 Apr 18, 2019

Show notes

Lynn Nichols Federal Tax Update Podcast

April, 18 2019, Episode 37

Listen as Lynn Nichols provides commentary on 6 Items pertaining to current developments in U.S. tax law.

IRS Explains Negative Tax Basis Capital Reporting Requirement

The IRS has responded to taxpayer concerns about a new partnership reporting requirement by providing definitions and real-world examples of what's required to be handed over to partners, but some practitioners are surprised by the clarifications.

[Tax Notes Today; 4/8/2019, article by Eric Yauch]

IRS Denies Exemption to Organization Formed to Support Accident Victim

The IRS denied tax-exempt status to an organization established to raise funds for an accident victim and his family because the organization is serving private rather than public purposes.

[LTR 201911008, 12/20/2018, rel. 3/15/2019]

(a) IRS Revises Practice Unit on Tax Home Determination

The IRS has revised a prior international practice unit on tax homes for purposes of section 911 to provide its staff with explanations of general international tax concepts and information about specific types of transactions.

(b) Practice Unit on Interest Capitalization Revised for TCJA Changes

The IRS has revised a prior practice unit to reflect changes made by the Tax Cuts and Jobs Act on the section 263A(f) requirement to capitalize interest if a taxpayer produces designated property, identifying taxpayers subject to section 263A(f) and the steps for determining how much interest must be capitalized to the basis of designated property.

Practice Unit on Construction Industry Accounting Methods Revised

The IRS has revised a prior practice unit, incorporating changes made by the Tax Cuts and Jobs Act, on land developers' and subcontractors' use of the completed contract method of accounting or the percentage of completion method for long-term contracts in the construction industry.

Business Consultant's Travel Expense Deductions Denied

The Tax Court, sustaining accuracy-related penalties, held that a consultant who operated a concierge chief financial officer business wasn't entitled to claim travel expense deductions under section 162, finding that his tax home was in New Jersey, where he had a three-year contract with a client, and not Atlanta where he and his family had a home.

[Michael E. Brown; No. 21096-15; T.C. Memo. 2019-30, 4/8/2019]

Tax Court Lacks Jurisdiction to Hear Suspended Corporations' Cases

The Tax Court held that it lacked jurisdiction to hear deficiency challenges by two corporations because the state of California had suspended their corporate rights prior to the filing of the petitions and that the revival of their corporate rights was beyond the time allotted to file a petition once a deficiency notice is received.

[Timbron International Corp. et al. T.C. Memo. 2019-31, 4/8/2019]

Fact Sheet Outlines Section 199A Deduction

The IRS has released a fact sheet (FS-2019-8) outlining the new section 199A deduction, which allows varying deduction amounts for qualified business income, qualified real estate investment trust dividends, and qualified publicly traded partnership income.

[FS-2019-8; 4/11/2019]

Federal Tax Update with Lynn Nichols #36 Mar 27, 2019

Show notes

Lynn Nichols Federal Tax Update Podcast

March, 27 2019, Episode 36

Listen as Lynn Nichols provides commentary on 4 Items pertaining to current developments in U.S. tax law.

Supporters of Clergy Housing Allowance Savor Court Win

Supporters of a long-standing clergy housing tax preference are breathing easier now that the provision has survived a court challenge over its constitutional

[Tax Notes Today; 3/18/2019, Article by Fred Stokeld]

Seventh Circuit Holds Housing Allowance Exclusion Constitutional

The Seventh Circuit reversed a district court decision and held constitutional section 107(2), which allows ministers to exclude from income a housing allowance paid to them as part of their compensation, finding that the exclusion doesn't violate the Establishment Clause.

[Annie Laurie Gaylor et al. v. Steven T. Mnuchin et al.; No. 18-1277; No. 18-1280, 3/15/2019]

Group Representing Auto Service Shops Denied Exemption

The IRS denied tax-exempt status to an organization seeking exemption as a business league because it operates primarily to help its independent auto service shop members obtain competitive supply pricing rather than helping the independent auto service industry as a whole.

[LTR 201907007; 9/10/2018, rel. 2/15/2019]

AND ANOTHER CASE IN WHICH EXEMPT STATUS IS REVOKED

Baseball Team Loses Exemption

The IRS revoked the tax-exempt status of an organization established to support a baseball team and promote baseball in the community after concluding the organization is a for-profit enterprise that does not operate primarily for exempt purposes.

[LTR 201907009; 10/24/2018, rel. 2/15/2019]

Individual Liable for Penalties for Timeshare Donation Scam

A U.S. district court, granting the government summary judgment, held that an individual who promised tax savings to individuals who donated their timeshares to a tax-exempt entity that he created based on his inflated appraisals of the timeshares is liable for penalties under section 6700. The court held that the penalty amounts remain in dispute.

[James Tarpey; USDC MT Butte Div., No. 2:17-cv-00094, 3/19/2019]

Pilot's Deductions for World War II Fighter Plane Denied

The Tax Court held that a pilot wasn't entitled to deductions in excess of the income he received for the restoration and maintenance of a World War II fighter plane because his activities were not for profit and he wasn't entitled to other unsubstantiated deductions. Also, the court held that the IRS didn't meet its burden under section 6751 regarding penalties.

[Edward G. Kurdziel Jr.; T.C. Memo. 2019-20, 3/21/2019]

Federal Tax Update with Lynn Nichols #35 Mar 20, 2019

Show notes

Lynn Nichols Federal Tax Update Podcast

March, 20 2019, Episode 35

Listen as Lynn Nichols provides commentary on 10 Items pertaining to current developments in U.S. tax law.

IRS Open to Additional Guidance on Portions of 199A

Nothing about the proposed real estate rental property safe harbor is set in stone, and further guidance on other one-off issues related to the passthrough deduction is a possibility, IRS officials said March 8.

[Tax Notes Today; 3/11/2019, Article by Eric Yauch]

Practitioners Call for 199A Soft Guidance, Safe Harbor Fix

Practitioners are welcoming IRS signals that it may reconsider its positions on the passthrough deduction rental safe harbor, saying the safe harbor isn't helpful.

[Tax Notes Today; 3/15/2019, Article by Eric Yauch]

Court Dismisses Challenge to IRS Levy on Social Security Benefits

A U.S. district court dismissed an individual's challenge to the IRS's levy on 100 percent of his Social Security benefits to collect his $20 million tax debt, finding that the suit is barred by the Anti-Injunction Act and the individual didn't show that any exception to the act applies; the court denied as futile his request to amend the complaint.

[Edward J. Holland Jr.; No. 2:17-cv-13926, 3/7/2019]

Fact Sheet Outlines TCJA Changes for Businesses

The IRS has released a fact sheet (FS-2019-3) summarizing tax law changes under the Tax Cuts and Jobs Act that affect businesses and provides resources to help business owners track down details specific to their concerns, noting that most of the changes took effect in 2018 and will affect returns filed in 2019.

[FS-2019-3, 3/8/2019]

Insurance Agents Group Denied Exemption

The IRS denied tax-exempt status to a group of insurance agents seeking exemption as a business league because the organization operates to benefit a specific insurance company rather than to improve the business conditions of insurance agents in general.

[LTR 201906014; 11/16/2018, rel. 2/8/2019]

Retroactive Social Security Benefits Stymie ACA Credit Claim

A lump-sum payment of retroactive Social Security benefits must be included in income for purposes of determining eligibility for the Affordable Care Act's premium tax credit, the Tax Court has held.

[Tax Notes Today; 3/12/2019, Article by Kristen Parillo]

Election Doesn't Protect Against Liability for Excess ACA Credits

The Tax Court, sustaining an IRS determination, held that an individual's modified adjusted gross income under section 36B to determine his eligibility for advance premium tax credits under the Affordable Care Act included all the Social Security benefits he received in that year despite a section 86(e) election to exclude a lump sum payment for the prior year.

[Levon Johnson; 152 T.C. No. 6, 3/11/2019]

Entity-Level Taxes Likely a Safer Bet for SALT Workarounds

Entity-level taxes used as state and local tax deduction cap workarounds are likely better able to withstand scrutiny than the creation of charitable funds, according to a practitioner.

[Tax Notes Today; 3/13/2019, Article by Andrea Muse]

Ninth Circuit Affirms Reduction of Estate's Charitable Deduction

The Ninth Circuit affirmed a Tax Court decision that sustained a tax deficiency and accuracy-related penalty against an estate, finding that the Tax Court properly upheld the IRS's reduction of a charitable deduction from the value of the property at the time of death because post-death events decreased the value of property actually given to the charity.

[Victoria E. Dieringer et al.; CA 9, No. 16-72640, 3/12/2019]

Power of Attorney, Extension Forms Fail to Update Address With IRS

The Tax Court, dismissing a deficiency case for lack of jurisdiction, held that forms a couple sent to the IRS with their new address after they had filed a return with their old address didn't provide clear and concise notification of a different address.

[Damian K. Gregory et ux.; 152 T.C. No. 7, 3/13/2019]

Court Won't Dismiss Former S Corp Shareholder's Suit for Breach

A U.S. district court refused to dismiss a former S corporation shareholder's suit against the remaining shareholders for breaching an agreement by refusing to agree to a section 1377 election to split the S corporation's tax year into two years according to the date his interest was terminated, which resulted in his owing additional taxes.

[Thomas S. Manfre v. David G. May et al.; USDC N Ill E Div., No. 1:18-cv-02184, 3/12/2019]

IRS Removes Reporting Requirement for Audit Regime Reps

The IRS has scaled back the amount of information individuals serving as partnership representatives under the audit regime must disclose on partnership returns.

[Tax Notes Today; 3/15/2019, Article by Eric Yauch]

Federal Tax Update with Lynn Nichols #34 Mar 14, 2019

Show notes

Lynn Nichols Federal Tax Update Podcast

March, 14 2019, Episode 34

Listen as Lynn Nichols provides commentary on 7 Items pertaining to current developments in U.S. tax law.

Federal Tax Update with Lynn Nichols #33 Mar 07, 2019

Show notes

Lynn Nichols Federal Tax Update Podcast

March, 07 2019, Episode 33

Listen as Lynn Nichols provides commentary on 8 Items pertaining to current developments in U.S. tax law. This week's topics include:

Organization Is Denied Tax-Exempt Status

The IRS denied tax-exempt status to an organization formed to develop programs to enrich and uplift the socio-economic well-being of its members, concluding that its organizing document doesn't limit the organization to charitable purposes and its activities consist of serving the private interests of its members.

[LTR 201904015; 11/1/2018, rel. 2/25/2019]

Medical Corporation Denied Exempt Status

The IRS denied tax-exempt status to a professional corporation formed by a public charity for the business purpose of practicing medicine, concluding that it was not organized for one or more exempt purposes.

[LTR 20190401; 10/31/2018, rel. 2/25/2019]

Supreme Court Says No to 3 Tax Challenges

The Supreme Court recently rejected petitions challenging excise taxes, the IRS's use of John Doe summonses, and deductions denied for horse-related activities.

[Tax Notes Today; 2/26/2019, Article by Patrice Gay]

Court Holds Estate Beneficiaries Liable for Unpaid Estate Tax

A U.S. district court, granting the government summary judgment, held that beneficiary family members are liable for an estate's unpaid tax liability because the undisputed facts show that each individual received property includable in the gross estate and that the federal estate tax was not paid when due.

[U. S. v. Donna Ringling et al.; USDC SD S Div., No. 4:17-CV-04006, 2/21/2019]

IRS Releases Revised Audit Technique Guide on Foreclosures, Debt Cancellation

The IRS has revised an earlier audit technique guide for examining cases involving real estate foreclosures and cancellation of debt income.

[Real Estate Property Foreclosure and Cancellation of Debt Audit Technique Guide, 2/22/2019, Revising 3/11/2015]

Application and Sequence: Limiting Business Loss and Interest

Richard Joslin explains how the new business loss and interest expense imitations work in tandem and affect other code provisions.

[Tax Notes Today; 2/27/2019, Article by Richard Joslin]

Fact Sheet Outlines TCJA Changes Affecting Individuals and Families

The IRS has released a fact sheet (FS-2019-2) outlining changes made by the Tax Cuts and Jobs Act, including changes affecting small business taxpayers and changes to withholding, deductions, benefits for dependents, the alternative minimum tax, and retirement plans.

[FS-2019-2; 2/26/2019,

IRS Releases Practice Unit on Self-Employment Tax and Partners

The IRS released a practice unit on when an individual partner's distributive share of income is subject to self-employment tax, noting that the unit applies to all arrangements that are treated as partnerships for federal tax purposes.

[PST/C/366_01_01-01; 26 Page Slide Show]

Federal Tax Update with Lynn Nichols #32 Feb 20, 2019

Show notes

Lynn Nichols Federal Tax Update Podcast

February, 20 2019, Episode 32

Listen as Lynn Nichols provides commentary on 7 Items pertaining to current developments in U.S. tax law. This week's topics include:

Split Circuit Court Affirms Partnership's Fee Awards

The government can be ordered to pay attorney fees under the qualified offer rule in a partnership proceeding under the 1982 Tax Equity and Fiscal Responsibility Act, the Federal Circuit held.

[Tax Notes Today; 2/11/2019, Article by Stephanie Cummings]

Federal Circuit Affirms Award of Litigation Costs to Partnership

The Federal Circuit affirmed a Court of Federal Claims decision that awarded a partnership litigation costs under section 7430 in its challenge to an untimely notice of final partnership administrative adjustment, holding that the partnership qualified as the prevailing party, that the amount of tax liability was in issue, and that the partnership incurred litigation costs.

[BASR Partnership et al. v. U.S.; Fed Cir, No. 17-1925, 2/8/2019]

DOJ Alerts Federal Circuit to Tax Court Order Related to Appeal

The government, in its appeal of a Court of Federal Claims decision that awarded litigation costs to a partnership, alerted the Federal Circuit to a recent Tax Court order that disagreed with the Court of Federal Claims and held that the qualified offer rule in section 7430 did not apply in a partnership proceeding because the amount of tax liability was not in issue.

[HURFORD INVESTMENTS NO. 2, LTD., HURFORD MANAGEMENT NO. 2, LLC,

Eleventh Circuit Affirms Conviction for Making False Claim to IRS

The Eleventh Circuit, in an unpublished per curiam opinion, upheld an individual's conviction for making a false claim to the IRS and corruptly impeding the administration of the internal revenue laws, finding that there was sufficient evidence that she fraudulently obtained a refund and moved the proceeds to evade detection and recovery by the IRS.

[U. S. v. Ingrid McBride Rich; CA 11, No. 17-15767, 2/12/2019]

Florida Tribe Seeks Review of Decision Holding Distributions Taxable

The Miccosukee Tribe of Indians of Florida petitioned the Supreme Court for review of an Eleventh Circuit decision that held that distribution payments a tribe member received from the tribe's gaming activities are not exempt from taxation, arguing that the payments were exempt as Indian general welfare benefits.

[Miccosukee Tribe of Indians of Florida v. United States; CA 11, No. 18-395, 1/7/2019]

IRS Addresses Bonus Depreciation Anomaly for Luxury Autos

The IRS has outlined procedures that will allow passenger car owners eligible for bonus depreciation to deduct depreciation during the recovery period that they wouldn't otherwise have been able to.

[Tax Notes Today; 2/14/2019, Article by Emily Foster]

IRS Provides Safe Harbor for Autos Eligible for Bonus Depreciation

The IRS has issued guidance (Rev. Proc. 2019-13) providing a safe harbor accounting method for determining depreciation deductions for passenger automobiles that qualify for the 100 percent additional first-year depreciation deduction under section 168(k) and that are subject to the depreciation limitations under section 280F(a).

[Rev. Proc. 2019-13; 2019-9 IRB 1, 2/13/2019]

AICPA Seeks Small Business Relief From Tax Shelter Definition

The American Institute of CPAs has asked that small businesses meeting specified conditions be excluded from the definition of a tax shelter so that they can obtain the benefits of the simplifying provisions of the Tax Cuts and Jobs Act.

[Letter Re: Small Business Relief from Definition of Tax Shelter, AICPA 2/13/2019]

IRS Now Asking About Negative Partnership Tax Capital Accounts

The IRS's ongoing interest in partners with negative tax basis capital accounts in partnerships has resulted in new instructions for filling out partnership tax returns.

[Tax Notes Today; 2/15/2019, Article by Nathan Richman]

Individual Entitled to Alimony Deduction for Arrearages Paid

The Tax Court held that an individual was entitled to an alimony deduction for alimony arrearages he paid to his former wife after a state court ordered him to do so or go to jail, finding that the arrearages maintained their character as alimony and were paid under a contempt order, not a money judgment as the IRS claimed.

[Jeffrey Siegel; No. 27572-16; T.C. Memo. 2019-11]

Federal Tax Update with Lynn Nichols #31 Feb 06, 2019

Show notes

Lynn Nichols Federal Tax Update Podcast

February, 06 2019, Episode 31

Listen as Lynn Nichols provides commentary on 3 Items pertaining to current developments in U.S. tax law. This week's topics include:

S Corporation Denied Deduction for Energy Efficient Buildings

A U.S. district court granted the government summary judgment in a suit seeking the return of erroneous refunds it made to a couple, finding that their electrical contracting S corporation wasn't entitled to deductions under section 179D for energy efficient commercial building property because the buildings were not placed in service in the year they claimed.

[United States v. Dennis F. Quebe et ux.; No. 3:15-cv-00294, 1/25/2019]

Fifth Circuit Vacates Late-Filing Penalty Decision for Government

The Fifth Circuit vacated a district court decision that held that a couple's reliance on their accountant to e-file their return didn't provide reasonable cause for their late filing and granted the government summary judgment, finding that there is a genuine dispute of material fact regarding whether the accountant's actions met the reasonable cause standard.

[Christopher A. Haynes; CA 5; No. 17-50816, 1,29,2019]

Tax Court Allows Partnership's $2.9 Million Worthless Debt Deduction

The Tax Court held that a partnership was entitled to a $2.9 million worthless debt deduction that the IRS disallowed, finding that there was a bona fide debt owed to the individual who contributed the note to the partnership in exchange for an interest in it and the debt became worthless in the year the partnership claimed the deduction.

[2590 Associates LLC et al.; No. 12924-16; T.C. Memo. 2019-3, 1/31/2019]

Federal Tax Update with Lynn Nichols #30 Jan 28, 2019

Show notes

Lynn Nichols Federal Tax Update Podcast

January, 28 2019, Episode 30

Listen as Lynn Nichols provides commentary on 2 Items pertaining to current developments in U.S. tax law. This week's topics include:

Treasury Opts for Taxpayer-Friendly Approach in 199A Regs

A new batch of guidance on the section 199A deduction aims to clarify taxpayers' concerns about an earlier proposal, while also taking a generous approach in expanding the number of businesses that can claim the tax break.

[Tax Notes Today; 1/22/2019, Article by Nathan Richman and Jonathan Curry]

Passthrough Regs Clarify Antiabuse Rules for Trusts

Treasury is looking to clear up some of the confusion regarding the application of its antiabuse rules to multiple trust arrangements under new section 199A passthrough deduction rules.

[Tax Notes Today; 1/22/2019, Article by Jonathan Curry]

IRS Issues Guidance Package on Section 199A Passthrough Deduction

The IRS has issued final regulations providing taxpayers with computational, definitional, and antiavoidance guidance on the deduction for qualified business income under section 199A. The regs adopt, with changes, proposed regs (REG-107892-18) issued in August.

[T.D. X?X?X?X; 1/18/2019]

Proposed Section 199A Regs Focus on Treatment of REIT Dividends

The IRS has issued proposed section 199A regulations (REG-134652-18) on the treatment of previously suspended losses that constitute qualified business income and on the determination of the section 199A deduction for taxpayers that hold interests in regulated investment companies, charitable remainder trusts, and split-interest trusts.

[REG-134652-18; 1/18/2019]

Passthrough Guidance Proposes Safe Harbor for Rental Real Estate Enterprises

The IRS has issued a proposed revenue procedure (Notice 2019-7) that provides a safe harbor under which a rental real estate enterprise will be treated as a trade or business solely for purposes of section 199A and concurrently issued final regulations.

[Notice 2019-7; 1/18/2019]

Passthrough Guidance Provides Methods for Calculating W-2 Wages

The IRS has issued a revenue procedure (Rev. Proc. 2019-11) providing three methods for calculating W-2 wages for purposes of section 199A(b)(2) and (7) and concurrently issued final regulations.

[Rev. Proc. 2019-11; 1/18/2019]

Warren Proposes New Tax on Wealthiest Americans

Americans with more than $50 million in assets would pay a new tax under a proposal from Sen. Elizabeth Warren, D-Mass.

[Tax Notes Today; 1/24/2019, Article by Asha Glover]

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