New “Repair Reg” Safe Harbor for Remodel-Refresh Expenses
On November 19, 2015, the Internal Revenue Service issued Revenue Procedure 2015-56. Rev. Proc. 2015-56provides certain retailers and restaurants a safe harbor method of accounting for remodel or refresh expenditures on qualified buildings, and helps eliminate confusion around which costs may be deducted immediately and which must be capitalized and depreciated over…
The New Jersey UTC: The Time Has Come
What is the Uniform Trust Code (UTC) and why should it be adopted in New Jersey? The Uniform Trust Code is, as the name denotes, an attempt to codify rules related to trust administration and planning. It was originally proposed by the National Conference of Commissioners on Uniform State Laws…
Other Recent NJ Estate Legislation
On January 19, 2016, Governor Christie signed 93 bills just before the 2014/2015 legislative session deadline ended. Bills that were not signed by noon on January 19th would have expired and would have needed to be reintroduced in the new legislative session. Nevertheless, among the bills signed are several affecting the…
Extenders Package Makes Various Credits & Deductions Permanent
On the morning of Dec. 18, the U.S. House of Representatives passed a $1.1 trillion spending bill and accompanying legislative package of tax extenders (the “Protecting Americans from Tax Hikes (PATH) Act of 2015”) by a vote of 316 to 113. A short time later, the U.S. Senate voted 56…
New Partnership Level Audit Rules
On November 2, 2015, the President signed into law the Bipartisan Budget Act of 2015 (the “Act”). The Act had numerous provisions, none of which relate to tax except almost the very last provision which now provides new rules for auditing partnerships. Under the Act, absent elections discussed below, all…
NJ Reduces Sales and Use Tax on Boats and Vessels
On December 9, 2015, Governor Christie signed into law, as P.L. 2015, c. 170, Senate Bill 2784 which provides a partial exemption and maximum sales and use taximposition for sales and uses of boats and vessels. The new law also establishes 30-day grace period for use tax imposition on certain boats…
New Code Section 7345 Could Jeopardize Passports for Taxpayers with Significant Tax Debts
On December 4, 2015, President Obama signed into law the “Fixing America’s Surface Transportation Act” (officially labeled the “FAST Act”) – P.L. 114-94. The bill’s primary takeaway is a 5-year, $305 billion plan to modify and modernize American transportation systems. However, hidden within the bill is a new Internal Revenue Code section…
FATCA and the New Frontier in Offshore Reporting Enforcement
* This article originally appeared in the October 2015 issue of Practical Tax Strategies, published by Thomson Reuters. Checkpoint Contents, Federal Library, Federal Editorial Materials, WG&L Journals, Practical Tax Strategies/Taxation for Accountants (WG&L) Practical Tax Strategies, 2015, Volume 95, Number 04, October 2015, Articles, FATCA AND THE NEW FRONTIER IN OFFSHORE REPORTING ENFORCEMENT, Practical Tax Strategies, Oct 2015 FATCA…
Tax Provisions from Congress’s New Highway Funding Bill
On July 31, President Barack Obama signed the Surface Transportation and Veterans Health Care Choice Improvement Act of 2015, H.R. 3236, into law. The Act makes many important changes to the Internal Revenue Code. For example, it requires additional information be included on mortgage interest returns, modifies basis reporting and…
Tax Court Upholds IRS Allocation of NOL Among Members of Consolidated Group
Four members of Marvel Entertainment Consolidated Group had Cancellation of Indebtedness (“COD”) income totaling $171,000,000 under IRC Section 108. The Taxpayer took the separate entity approach in reducing the group’s net operating loss carryforward by the amount of COD income. The Taxpayer first allocated to the four members their share of the…