Bloomberg Tax

State Workarounds for the $10,000 SALT Cap Are Now the Norm

The week in state tax news: Iowa, Hawaii, Montana, and Nebraska have all acted on legislation creating “SALT cap workarounds” this month. Also, the Supreme Court offered some views on what should happen to surplus proceeds when a property is seized and sold to settle tax debts.

Tax Developments

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IRS PLR: Extension Granted to File Form 8996 for Election to Self-Certify as Qualified Opportunity Fund (IRC §1400Z)

The IRS has published a private letter ruling on Section 1400Z and Treasury Regulation Section 301.9100 regarding extensions of time to self-certify as a Qualified Opportunity Fund. [PLR 202321003]

IRS PLR: S Corporation Termination Inadvertent (IRC §1362)

The IRS has published a private letter ruling on Section 1362 regarding S corporation election, revocation, or termination. [PLR 202321002]

IRS PLR: Medical Innovation Set-Aside Approved (IRC §4942)

The IRS has published a private letter ruling on Section 4942 regarding taxes on failure to distribute income. [PLR 202321017]

IRS Chief Talks Goals, Work with Congress, and More

Treasury's Adeyemo Talks Energy Credits Implementation

Black Tax Pro Highlights Benefits of Small Business

GOP Taxwriter Prioritizes Oversight This Congress

From the Analysts

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More SALT Workarounds Ahead as States Add Pass-Through Tax

Differences in the application of extensions, retroactivity, estimated payments, and credits remain the key elements that practitioners must navigate when dealing with the varying approaches to pass-through entity taxes.

BTAX OnPoint: Quick Guide to Preparing for ESG Reporting Rules

Despite a lack of mandatory reporting requirements in the US, more companies are choosing to adopt environmental, social, and governance (ESG) frameworks.

Estate of Block Ruling Shows Need for Care With Trust Planning

In Estate of Block v. Commissioner, the Tax Court scrutinized the purported charitable remainder annuity trust (CRAT) and denied the estate’s claimed charitable deduction for the remainder interest because the CRAT’s income interest provision did not comply with the law and the trustees failed to correct the error quickly enough.

Free Tax Filings Threaten $4 Billion TurboTax Business

Bloomberg Tax Journals

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Intragroup Financial Guarantees Drive MNE Transfer Pricing Plans

Financial transactions are considered to be one of the most significant areas of transfer pricing controversy between taxpayers and tax authorities. On Feb. 11, 2020, the OECD released transfer pricing rules with respect to financial transactions that were then included in chapter X of the 2022 OECD Transfer Pricing Guidelines, and in 2021, the UN included Chapter 9.13 of the 2021 UN Practical Manual to provide guidance for taxpayers and tax authorities on how to analyze and price financial guarantees in transfer pricing.

New IFRS 17 Will Affect Many Companies With Insurance Contracts

IFRS 17, international reporting standards for insurance contracts, has implications not only for accounting and finance, but also taxes, policies, and processes, says Mhalou Abadiano of Stout’s Transaction Advisory group.

Tribunal Rules on the Tax Treatment of Share Class Redemptions

ATOZ Tax Advisers authors Oliver R. Hoor, Keith O’Donnell, and Samantha Schmitz analyze potential implications of Luxembourg’s January 2023 Administrative Tribunal’s ruling on the tax treatment of the redemption of a class of shares by a Luxembourg company.

Latest Stories

Biden, McCarthy Voice Confidence Debt Deal Will Pass in Time

President Joe Biden and House Speaker Kevin McCarthy expressed confidence that their debt-ceiling deal will pass Congress, averting a historic US default while setting a course for federal spending until after the 2024 election.

From Across Bloomberg Law

Crypto News Daily Tax Report: International Daily Tax Report: State The Exchange: Tax Insights & Commentary
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  • The Exchange: Tax Insights & Commentary

Luxury Concierge Service Was Illegal Private Bank, US Says (1)

A businessman who claimed to operate a high-end concierge service featuring custom credit cards crafted from solid gold was actually operating an illegal private bank that provided discreet financial services to high-net-worth customers, prosecutors said.

FINANCE BRIEFING: Debt Deal Takes Shape With Two Year Cap

Republican and White House negotiators are moving closer to an agreement to raise the debt limit and cap federal spending for two years, according to people familiar with the matter. The details agreed to are tentative and a final accord is still not in hand. Plus, the two sides have yet to agree on the amount of the cap.