Posts by Rosanna DiFilippo

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Proposed Income Regulations Provide Clarity for Accrual Method Taxpayers

On September 5, 2019, the IRS and Treasury released proposed regulations addressing the timing of…

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Proposed Regulations on Tax Treatment of Revenues from Cloud and Digital Content Transactions

The Internal Revenue Service (IRS) and the Department of Treasury (Treasury) recently released proposed regulations…

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Proposed FDII Regulations Provide Taxpayers With Guidance

Effective for tax years beginning after December 31, 2017, corporate taxpayers that engage in certain…

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IRS to Keep Ruling on Section 355 Transactions After Pilot Program Ends

The pilot program has been significant for taxpayers seeking greater certainty on the tax consequences…

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Applying Section 83(I) Deferral of Tax Payment

On December 7, 2018, the IRS issued guidance on the application of Internal Revenue Code…

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New Guidance to be Issued on Previously Taxed Earnings and Profits

Recently, the Department of the Treasury and the Internal Revenue Service issued Notice 2019-01. The Notice…

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Massachusetts Enacts Supplemental Appropriations Bill

For corporate excise tax and financial institution tax purposes, H. 4930 generally provides a 95-percent…

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Federal Tax Reform Opportunity Zones

The establishment of newly created Federal Opportunity Zones was added to the Internal Revenue Code…

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New Automatic Changes for Small Businesses Meeting the $25 Million Gross Receipts Test

On August 3, 2018, the IRS released Rev. Proc. 2018-40, which provides procedural guidance by…

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Net Operating Losses (NOLs) In the Wake of Tax Reform

Previously, business’s net operating losses could be carried back two (2) years and carried forward…

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