FL - Guidance issued on affidavit required to claim exemption for boats sold to nonresident purchasers
Guidance is issued regarding changes that have been made to the affidavit required to claim the sales tax exemption for […]
Read MoreFinal regulations under Code Sec. 301 update the existing regulations under this provision to reflect statutory changes made by the Technical and Miscellaneous Revenue Act of 1988 ( P.L. 100-647) (the 1988 Act). These changes generally provide that the amount of a Section 301 distribution of property made by a corporation to its shareholder is the fair market value of the distributed property. The final Section 301 regulations adopt prior proposed regulations ( NPRM REG-121694-16), without substantive changes, and apply generally to distributions made after September 22, 2021.
Code Sec. 301 and Amendments by the Technical and Miscellaneous Revenue Act of 1988
Code Sec. 301 provides rules for the treatment of a distribution of property, including money, made by a corporation to its shareholder with respect to that shareholder’s stock ownership in that corporation (a Section 301 distribution).
The 1988 Act amended Code Sec. 301(b)(1) to provide that the amount of any Section 301 distribution is the amount of money received plus the fair market value of the other property received. The 1988 Act also amended Code Sec. 301(d) to provide that the basis of property received in a Section 301 distribution is the fair market value of such property (both amendments, collectively, are referred to as the 1988 amendments).
The current Section 301 regulations reflect the rules of these two provisions as they existed prior to the 1988 amendments. Accordingly, to the extent preempted by statute, the current regulations have no application.
2019 Proposed Regulations
In 2019, the IRS issued proposed regulations under Code Sec. 301 ( NPRM REG-121694-16) to reflect the 1988 amendments (2019 proposed regulations). The scope of the 2019 proposed regulations was limited to:
Final Regulations
The final Section 301 regulations adopt the 2019 proposed regulations with no substantive changes and with certain non-substantive changes for purposes of clarity and readability. The final regulations apply to Section 301 distributions made after September 22, 2021. However, these regulations update the previous regulations under Code Sec. 301 to reflect the statutory changes made by the 1988 Act, which apply to distributions made in tax years beginning after December 31, 1986.
Guidance is issued regarding changes that have been made to the affidavit required to claim the sales tax exemption for […]
Read MoreThe Florida Department of Revenue is offering corporate income tax return filing extensions for businesses in counties affected by severe […]
Read MoreFlorida issued guidance that discusses the new corporate income tax credit for employing individuals with unique abilities. The guidance includes […]
Read MoreFlorida issued guidance that discusses the new corporate income tax credit for employing individuals with unique abilities. The guidance includes […]
Read MoreThe IRS has announced plans to deny tens of thousands of high-risk Employee Retention Credit (ERC) claims while beginning to process lower-risk claims. The agency’s review has […]
Read MoreThe IRS has issued a warning about the increasing threat of impersonation scams targeting seniors. These scams involve fraudsters posing as government officials, including IRS agents, […]
Read MoreThe IRS released the inflation adjustment factors and the resulting applicable amounts for the clean hydrogen production credit for 2023 and 2024. For 2023, the inflation adjustment factor is one, so the inflation adjusted applicable amounts are the same as those in Code Sec. 45V(b). Thus, the applicable amounts for a […]
Read MoreThe IRS has released the inflation adjustment factor for the credit for carbn dioxide (CO2) sequestration under Code Sec. 45Q for 2024. The inflation adjustment factor is 1.3877, and the credit is $27.75 per metric ton […]
Read MoreThe United States has provided formal notice to the Russian Federation on June 17, 2024, to confirm the suspension of the operation […]
Read MoreThe IRS issued frequently asked questions (FAQs) related to distributions from retirement plans and IRS for individuals impacted by federally declared disasters. These FAQs cover the ongoing disaster relief for certain distributions […]
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