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Accounting for Income Taxes — Quarterly Hot Topics: January 2019

Published on: Jan 07, 2019

Topics covered in this issue include the following tax law developments:

Tax law developments

  • U.S. Federal:
    • Treasury and the IRS recently issued proposed Treasury Regulations and Notices related to the Tax Cuts and Jobs Act (the “Tax Act”):
      • New IRC section 163(j) proposed regulations released.
      • Foreign Tax Credit proposed Treasury Regulations released.
      • Base Erosion Avoidance Tax proposed Treasury Regulations released.
      • IRC sections 245A and 267A proposed Treasury Regulations released.
  • U.S. Federal Tax Accounting Methods and Periods:
    • Beginning of construction rules issued for the energy investment tax credit.
    • Final Treasury Regulations under IRC section 263A released.
    • Notice 2018-99 provides guidance for parking expenses for qualified transportation fringe benefits.
    • Investing in Qualified Opportunity Funds (qualified Opportunity Zone Incentive).
  • U.S. Federal Financial Instruments:
    • The commitment fees paid on a revolving loan as deductible in the year incurred upheld by the IRS.
  • U.S. Federal Employee Benefits:
    • Notice 2018-97 released.
  • U.S. International:
    • IRC section 956 proposed Treasury Regulations released.
    • Notice 2019-01: previously taxed earnings and profits accounts guidance released.
  • U.S. Partnerships:
    • IRC section 864(c) proposed Treasury Regulations released.
  • U.S. Multistate:
    • New state judicial updates:
      • California, Colorado, Illinois, Iowa, Kentucky, New Jersey, Ohio, Puerto Rico, Texas, Utah and Wisconsin.
    • Multistate tax considerations of the Tax Act:
      • Proposed IRC section 965 and GILTI Regulations may result in federal/state income tax differences.
    • New legislative updates:
      • Arkansas, Georgia, Iowa, Louisiana, Maine, Maryland, Massachusetts, Missouri, Montana, New York City, New Jersey, Oklahoma, Oregon, and South Carolina.
    • Amnesty Voluntary Disclosure:
      • New Jersey.

Accounting Developments

  • FASB amends guidance on cloud computing arrangements.
  • FASB discusses feedback on proposed disclosure requirements related to income taxes.

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