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Internal Revenue Service Inventory

The United States Internal Revenue Service is a bureau of the United States Department of the Treasury. The IRS is charged with collecting revenue and enforcing the Internal Revenue Code.  
Holland & Knight LLP

Proposed Rule Modifies Timing of "Hot Asset" Reporting

Holland & Knight LLP on

Generally, gain or loss on the sale or exchange of a partnership interest is treated as capital gain or loss except to the extent of so-called "hot assets." Gain attributable to hot assets – generally unrealized receivables...more

Eversheds Sutherland (US) LLP

IRS provides welcome flexibility and clarification in final small business tax accounting regulations

On Wednesday, December 23, Treasury and the IRS released final regulations under sections 263A, 448, 460, and 471 of the Internal Revenue Code (Code) to implement statutory changes made by the Tax Cuts and Jobs Act (the...more

Alston & Bird

Sourcing the Source of Inventory Sales – Final Regulations Under Section 863(b)

Alston & Bird on

Is inventory personal? Well, it depends. Our International Tax Group explores the finalized sourcing rules that decide whether inventory is U.S. or foreign source after changes wrought by the Tax Cuts and Jobs Act....more

Fenwick & West LLP

Proposed Guidance on the Production Sourcing Rules under New Section 863(b)

Fenwick & West LLP on

The Tax Cuts and Jobs Act (TCJA) repealed the long-standing “50/50” sourcing rule for United States exporters of manufactured products. Under the new rules, which source income of a “producer” solely to the place of...more

Miles & Stockbridge P.C.

Debt Secured by Inventory Real Property is Not QRPBI

In the recently released Revenue Ruling 2016-15, the IRS determined that discharge of debt income generated by the forgiveness of debt secured by real property constituted excludable qualified real property business...more

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