188bet亚洲真人体育下载 asks Treasury and IRS to clarify S corporation issues arising from 税 Cuts and Jobs Act

的 美国注册188bet亚洲真人体育下载 美国注册188bet亚洲真人体育下载(188bet亚洲真人体育下载)已要求美国政府立即提供指导.S. Department of the Treasury and the Internal Revenue Service (IRS) on various S corporation items included in the 税 Cuts and Jobs Act (TCJA). 

“税payers and practitioners need clarity on S corporation issues in order to comply with their 2018 tax obligations and to make informed decisions regarding cash-flow, 实体结构, 以及税务规划问题,“安妮特·内伦, 188bet亚洲真人体育下载网址, CGMA, 收., chair of the 188bet亚洲真人体育下载 税 Executive Committee chair, wrote in the 信.

Nellen identified certain items affecting S corporations that the 188bet亚洲真人体育下载 believes the Treasury Department and the IRS should address in the coming months.  “Our 信 includes both the 188bet亚洲真人体育下载 priority issues and the recommendations to resolve these issues,她说。. 

Specifically, Nellen recommended that Treasury and IRS provide the following items:

• Guidance on the application of the new laws on loss carryforwards.
  • Clarify how to coordinate various loss and deduction limitations with Internal Revenue Code section 199A qualified business income (QBI) carryover losses by applying the order as follows: section 163(j), 1366(d), 第465节, 第469节, 第461节(左), 及第199A条.
  • Clarify that the carryforward rule under section 163(j)(2) applies to S corporations despite section 1371(b)(2).
  • Clarify the definition of real property trades or businesses beyond 第469节(c)(7)(C) for purposes of the disallowed business interest deduction under section 163(j).
  • Clarify the application of the 第461节(左) limitation on net operating losses.
• Guidance on certain provisions relating to the post-termination transition period (PTTP) and the eligible terminated S corporation (ETSC) period under Internal Revenue Code section 1371(f).
  • Clarify how a corporation computes its accumulated adjustments account (AAA) upon re-electing S corporation status if the corporation was an ETSC and if the corporation was not an ETSC.
  • Clarify how the ETSC Period rules of section 1371(f) apply when a corporation has more than one PTTP.
  • Identify the shareholders eligible to receive distributions from a corporation’s AAA during the ETSC Period.
  • Clarify how distributions are allocated between the AAA and accumulated earnings and profits (AE&P)根据第1371(f)条.
  • 阐明在PTTP和ETSC期间如何调整AAA.
• Guidance on the treatment of deferred foreign income upon transition to participation exemption system of taxation (Internal Revenue Code section 965) for S corporation trust shareholders and what trust transactions are section 965 triggering events and how a transferee of S corporation stock held in trust might assume the liability for the section 965 transition tax.
  • Clarify that transition tax on deferred foreign income is not triggered by transfer to an irrevocable grantor trust or a revocable grantor trust.
  • Provide clarity regarding the assumption of the section 965 transition tax liability on the death of the grantor of a grantor type irrevocable trust that holds S corporation stock, as well as on the death of the grantor of a revocable trust making the section 645 election.
  • Provide clarity regarding a qualified subchapter S trust (QSST) and whether the trust or the beneficiary assumes the liability for the section 965 transition tax.
  • Provide clarity on whether a QSST conversion to an electing small business trust (ESBT) conversion, 或ESBT到QSST的转换, is a triggering event for purposes of the section 965 transition tax.
  • Provide clarity on whether the severance or division of a trust into separate shares is a triggering event for purposes of the section 965 transition tax.
  • Provide clarity on the material modifications in trusts or trust beneficiaries that Treasury and the IRS would treat as a triggering event for purposes of section 965(i)(2)(A)(iii).