New Law. The Act retroactively and permanently extends the 100% exclusion and the exception from minimum tax preference treatment. ( Code Sec. 1202(a)(4) , as amended by Act Sec. 126(a))
New Law. The Parties recognize that City presently is required by law to defend the validity of any voter-approved City initiative or referendum. The undertaking and provision of any such defense by City shall not be construed in any manner as a violation or default of this Agreement.
New Law. The Act retroactively and permanently extends the research credit. ( Code Sec. 41(h) , as amended by Act Sec. 121(a)(1)) In addition, for tax years that begin after Dec. 31, 2015, eligible small businesses ($50 million or less of gross receipts) may claim the credit against their alternative minimum tax (AMT) liability. ( Code Sec. 38(c)(4)(B)(ii) , as amended by Act Sec. 121(b)) And, for tax years that begin after Dec. 31, 2015, small (less than $5 million of gross receipts) startup businesses may claim up to $250,000 per year of the credit against their employer FICA tax liability. ( Code Sec. 41(h) and Code Sec. 3111(f), as amended by Act Sec. 121(c)) Exemption for RIC Interest-Related Dividends and Short-Term Capital Gains Dividends Permanently Extended Under pre-Act law, a regulated investment company (RIC) may designate and pay (1) interest-related dividends out of interest that would generally not be taxable when received directly by a nonresident alien individual or foreign corporation, and (2) short-term capital gains dividends out of short-term capital gains. RIC dividends designated as interest-related dividends and short-term capital gains dividends are generally not taxable when received by a nonresident alien individual or foreign corporation and aren't subject to the withholding tax imposed on nonresident alien individuals and foreign corporations. Under pre-Act law, these provisions didn't apply to dividends with respect to any tax year of a RIC beginning after Dec. 31, 2014.
New Law. The Act retroactively and permanently extends the rules exempting from gross basis tax and withholding tax the interest-related dividends and short-term capital gain dividends received from a RIC. ( Code Sec. 871(k) , as amended by Act Sec. 125)
New Law. The Act retroactively and permanently extends the PPA rule. ( Code Sec. 1367(a)(2) , as amended by Act Sec. 115(a))
New Law. The Act retroactively and permanently extends these rules. ( Code Sec. 512(b)(13)(E)(iv) , as amended by Act Sec. 114(a)) Liberal Rule for Corporate Qualified Conservation Contributions Permanently Extended and Expanded A corporation that, for the tax year of the contribution, is a qualified xxxxxx or rancher and whose stock isn't readily tradable on an established securities market at any time during that year may take a deduction for qualified conservation contributions up to 100% of its taxable income, after taking into account other allowable charitable contributions, with a 15-year carryover of such contributions in excess of the applicable limitation. Under pre-Act law, these rules didn't apply to any contribution made in a tax year beginning after Dec. 31, 2014, and contributions made thereafter by corporations can't exceed 10% of its taxable income, with a 5- year carryover of such contributions in excess of the applicable limitation. New law. The Act retroactively and permanently extends the 100% limitation on qualified conservation contributions of real property. ( Code Sec. 170(b)(1)(E) , as amended by Act Sec. 111(a)) And, for contributions made in tax years beginning after Dec. 31, 2015, the Act provides that Alaska Native Corporations (as defined in section 3(m) of the Alaska Native Claims Settlement Act) are allowed to deduct donations of conservation easements up to 100% of taxable income. ( Code Sec. 170(b)(2)(C) , as amended by Act Sec. 111(b)) Enhanced Deduction for Food Inventory Permanently Extended and Expanded A taxpayer engaged in a trade or business is eligible to claim an enhanced deduction for donations of food inventory. A C corporation's deduction equals the lesser of (a) basis plus half of the property's appreciation, or (b) twice the property's basis, for contributions of food inventory that was apparently wholesome food-i.e., meant for human consumption and meeting certain quality and labeling standards. For a taxpayer other than a C corporation, the aggregate amount of contributions of apparently wholesome food that may be taken into account for the tax year can't exceed 10% of the taxpayer's aggregate net income for that tax year from all trades or businesses from which those contributions were made for that tax year. Under pre-Act law, this enhanced charitable deduction didn't apply for contributions after Dec. 31, 2014. New law. The Act retroactively and permanently extends the apparently wholesome food contribution rule...
New Law. The Act retroactively and permanently extends the credit. ( Code Sec. 45P(f) , as amended by Act Sec. 122(a)) And, for tax years beginning after Dec. 31, 2015, the Act provides that the credit applies to employers of any size (i.e., the less than 50 employee average no longer applies). ( Code Sec. 45P(a) , as amended by Act Sec. 122(b))
New Law. The Act retroactively extends the WOTC so that it applies to eligible veterans and non-veterans who begin work for the employer before Jan. 1, 2019. (Code Sec. 51(c)(4)(B), as amended by Act Sec. 142(a)) With respect to individuals who begin work for an employer after Dec. 31, 2015, the credit also applies to employers who hire qualified long-term unemployed individuals (i.e., those who have been unemployed for 27 weeks or more). The credit with respect to such long-term unemployed individuals is 40% of the first $6,000 of wages. (Code Sec. 51(d)(1)(J) and Code Sec. 51(d)(15), as amended by Act Sec. 142(b)) Look-Through Rule for Payments Between Related CFCs under Foreign Personal Holdin Company Income Rules Extended Through 2019 For tax years beginning before Jan. 1, 2015, dividends, interest, rents, and royalties received by one controlled foreign corporation (CFC) from a related CFC are not treated as foreign personal holding company income (FPHCI) to the extent attributable or properly allocable to non-subpart-F income, or income that was not effectively connected with the conduct of a U.S. trade or business of the payor (look- through treatment). Under pre-Act law, this look-thru rule applied to tax years of foreign corporations beginning after Dec. 31, 2005 and before Jan. 1, 2015, and to tax years of U.S. shareholders with or within which such tax years of foreign corporations ended. New law. The Act retroactively extends look-through treatment for related CFCs for five years, to tax years of a foreign corporation before Jan. 1, 2020, and tax years of U.S. shareholders with or within which such tax years of foreign corporations end. ( Code Sec. 954(c)(6)(C) , as amended by Act Sec. 144(a))
New Law. The Act retroactively extends the Indian employment credit for two years to tax years beginning before Jan. 1, 2017. ( Code Sec. 45A(f) , as amended by Act Sec. 161(a))
New Law. The Act retroactively and permanently extends the rules exempting from gross basis tax and withholding tax the interest-related dividends and short-term capital gain dividends received from a RIC. Treatment of RIC As Qualified Investment Entity Permanently Extended Gain from the disposition of a U.S. real property interest (USRPI) by a foreign person is treated as income effectively connected with a U.S. trade or business and is subject to tax and to withholding under the Foreign Investment in Real Property Tax Act (FIRPTA) provisions. A USRPI does not include an interest in a domestically controlled "qualified investment entity". Under pre-Act law, before January 1, 2015, a RIC that met certain requirements could be treated as a "qualified investment entity". New law. The Act retroactively and permanently extends the inclusion of a RIC within the definition of a "qualified investment entity." The change made generally takes effect on January 1, 2015, but the Act doesn't impose a withholding requirement for any payment made before its enactment. A RIC that withheld and remitted tax on distributions made after December 31, 2014 and before the enactment date isn't liable to the distributee for such withheld and remitted amounts.
