Example 1: A new S corporation that has a required calendar
tax year could make a Sec.
8.42% thought the
tax year end was April 1st, equal to 4,081,872 adults.
179 to deduct as a current expense, instead of claiming depreciation, up to a specified amount of the cost of new or used tangible personal property placed in service during the
tax year in the taxpayer's business.
(3) Global interest netting should apply only to
tax years that are not barred by statute.
All the facts and circumstances of the situation indicate that you and/or your spouse participated in the operation of your woodland activity on a regular, continuous, and substantial basis during the
tax year. The specific rules to be followed in applying this test were not part of the first set of regulations, but will be addressed in future regulations.
An LLC can apply for a nonautomatic change in
tax year if it can show it has a natural business year.
For
tax years beginning after 2004, the new law establishes a uniform definition of qualifying child for purposes of these five benefits.
CPAs should advise clients that, under the act's section 401(h), the new provisions apply to
tax years beginning after 2001.
Hence, where an earlier examination cycle -- say the taxpayer's 1989 and 1990
tax years -- require three to four years to resolve, the later 1991 and 1992 examination cycle may "catch up" in Appeals or litigation and ultimately be joined with the earlier cycle for resolution.
Under the majority-interest rule, an LLC must adopt the same
tax year as that of its member or members who cumulatively own more than 50% of the LLC's profits and capital interests.
When the CFC's
tax year coincides with the shareholder's
tax year, the subpart F income is included on the final day of the shareholder's
tax year.
If a taxpayer elects to apply retroactively the revised netting rule, the 110-percent limitation should apply to the first taxable year that follows the original base-period years and becomes a part of the second
tax year's FBPR and debt-to-asset data.