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 MoreThe IRS intends to amend the base erosion and anti-abuse tax (BEAT) regulations under Code Secs. 59A and 6038A to defer the applicability date of the reporting of qualified derivative payments (QDPs) until tax years beginning on or after January 1, 2025.
Final BEAT regulations adopted with T.D. 9885 include rules under Code Secs. 59A and 6038A addressing the reporting of QDPs, which are not treated as base erosion payments for BEAT purposes. The final regulations generally apply to tax years ending on or after December 17, 2018.
In general, a payment qualifies for the QDP exception if the taxpayer satisfies certain reporting requirements. Reg. §1.6038A-2(b)(7)(ix) requires a taxpayer subject to the BEAT to report on Form 8991, Tax on Base Erosion Payments of Taxpayers With Substantial Gross Receipts, the aggregate amount of QDPs for the tax year, and make a representation that all payments satisfy the reporting requirements of Reg. §1.59A-6(b)(2). If a taxpayer fails to satisfy these reporting requirements with respect to any payments, those payments are not eligible for the QDP exception and are treated as base erosion payments, unless another exception applies.
The QDP reporting rules of Reg. §1.6038A-2(b)(7)(ix) apply to tax years beginning on or after June 7, 2021. Before these rules are applicable (the transition period), a taxpayer is treated as satisfying the QDP reporting requirements to the extent that the taxpayer reports the aggregate amount of QDPs on Form 8991, Schedule A, provided that the taxpayer reports this amount in good faith ( Reg. §1.59A-6(b)(2)(iv); Reg. §1.6038A-2(g)).
In Notice 2021-36, I.R.B. 2021-26, 1227, the IRS announced the intention to extend the transition period through tax years beginning before January 1, 2023, while the IRS studies the interaction of the QDP exception, the BEAT netting rule in Reg. §1.59A-2(e)(3)(vi), and the QDP reporting requirements. The IRS has not yet issued regulations amending the applicability date of Reg. §1.6038A-2(g). The IRS continue to study these provisions and has determined that it is appropriate to further extend the transition period.
The IRS intends to amend Reg. §1.6038A-2(g) to provide that the QDP reporting rules of Reg. §1.6038A-2(b)(7)(ix) will apply to tax years beginning on or after January 1, 2025. Until these rules apply, the transition period rules described above will continue to apply. Taxpayers may rely on this Notice before the amendments to the final regulations are issued.
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 […]
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