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Consolidated Appropriations Act, 20202019 Year-End Tax Planning2019 Post-Filing Season Update2018 Year-End Tax Planning
IRS Updates Rules on Using Per Diem Rates to Substantiate Expenses Incurred Away from Home
The IRS has updated Rev. Proc. 2011-47 to reflect changes made by the Tax Cuts and Jobs Act (TCJA) ( P.L. 115-97).The guidance provides the rules for determining the amount of an employee's ordinary a...
Electronic Filing Now Required for Requesting Unused Low-Income Housing Credit Carryover
The IRS has released guidance to qualified states regarding how to request an allocation of unused housing credit carryover under Code Sec. 42(h)(3)(D)(iii). The new guidance requires allocation reque...
IRS Extends Certain Deadlines, Penalty Relief for Health Coverage Forms
Health insurance providers (including employers and health insurance companies) now have until March 2, 2020, to furnish to individuals Form 1095-B, Health Coverage, and Form 1095-C, Employer-Provided...
Interim Amendments for Hardship Distributions Clarified and Deadline Extended
The IRS has clarified which amendments are integral to a plan provision that fails to satisfy the qualification requirements by reason of a change made by the final hardship distribution regulations. ...
2019 Required Amendments List for Employee Plans
The IRS has issued its 2019 Required Amendments List (2019 RA List) for individually designed employee retirement plans. Beginning with the 2019 list, all RA Lists will apply to both Code Sec. 401(a) ...
Date Extended for Applying Foreign Branch Rules
A one-year extension has been granted for applying the Code Sec. 987 final regulations, and certain related final and temporary regulations covering foreign branch transactions of U.S. corporations. T...
Guidance Updated for Making Adequate Disclosure
The IRS has updated its guidance that identifies circumstances under which a disclosure on a taxpayer's income tax return with respect to an item or position is "adequate" for reducing the under...
IRS Releases 2020 Inflation-Adjusted Tax Tables, Other Amounts
The IRS has released the annual inflation adjustments for 2020 for over 60 tax provisions, including the income tax rate tables. The IRS issues these cost-of-living adjustments (COLAs) each year to re...
2020 Inflation Adjustments for Pension Plans, Retirement Accounts
The IRS has released the 2020 cost-of-living adjustments (COLAs) for pension plan dollar limitations, and other retirement-related provisions.Highlights of 2020 ChangesThe contribution limit for emplo...
IRS Updates Guidance on Computing Deductions for Operating a Vehicle
The IRS has released guidance that updates Rev. Proc. 2010-51, I.R.B. 2010-51, 883 to reflect changes made to Code Secs. 67 and 217 by the Tax Cuts and Jobs Act (TCJA) ( P.L. 115-97). Rev. Proc. 2010-...
Accounting Method Change Procedures Updated
The IRS has released guidance listing the specific changes in accounting method to which the automatic change procedures in Rev. Proc. 2015-13, I.R.B. 2015-5, 419, apply. This guidance updates and sup...
Proposed Updated RMD Tables Issued
The IRS has proposed updated life expectancy and distribution period tables under the required minimum distribution (RMD) rules. The proposed tables reflect the general increase in life expectancy, an...
Joint Directive on Work Opportunity Tax Credit Issued
The IRS Large Business and International Division (LB&I) and Small Business/Self-Employed Division (SBSE) have issued a joint directive to provide instructions to LB&I and SBSE examiners on th...
New LB&I Campaign on Deferred Foreign Income
The IRS Large Business and International (LB&I) has added a new active campaign to the IRS website called "IRC 965." The campaign's goal is to promote compliance with Code Sec. 965, Treatmen...
IRS Highlights Steps For Smooth Processing of Taxpayers' 2019 Federal Tax Returns
The IRS urged taxpayers to act now to ensure the smooth processing of their 2019 federal tax return. This reminder, first in a series, was aimed to help taxpayers get ready for the upcoming tax filing...
MA - Final guidance on IRC Sec. 163(j) interest expense limitation issued
Massachusetts issued final guidance for corporate excise taxpayers on the IRC Sec. 163(j) business interest expense (BIE) limitation.What Is the BIE Limitation?Under IRC Sec. 163(j), a taxpayer's busi...
New Rules Proposed on Charitable Contribution Related to SALT Benefits
The IRS has released new proposed rules related to charitable contributions made to get around the $10,000/$5,000 cap on state and local tax (SALT) deductions. The proposed regulations:
incorporate the safe harbor in Notice 2019-12 for individuals who have any portion of a charitable deduction disallowed to the receipt of SALT benefits;
incorporate the safe harbor in Rev. Proc. 2019-12 for business entities to deduct certain payments made to a charitable organization in exchange for SALT benefits; and
clarify the application of the quid pro quo principle under Code Sec. 170 to benefits received or expected to be received by the donor from a third party.
SALT Limit
An individual's itemized deduction of SALT taxes is limited to $10,000 ($5,000 if married filing separately) for tax years beginning after 2017. Some states and local governments have adopted laws that allowed individuals to receive a state tax credit for contributions to certain charitable funds. These laws are aimed at getting around the SALT deduction limit by creating a charitable deduction for federal income tax purposes.
The IRS issued final regulations in June 2019 that provide that the receipt of a SALT credit for a charitable contribution is the receipt of a return benefit (quid pro quo benefit). Thus, the taxpayer must reduce any contribution deduction by the amount of any SALT credit received or expected to receive in return. The regulations contain a de minimis exception if the SALT credit does not exceed 15 percent of the taxpayer's charitable payment.
A taxpayer is not required to reduce the charitable contribution deduction because of the receipt of SALT deductions. However, the taxpayer must reduce the charitable deduction if it receives or expects to receive SALT deductions in excess of the taxpayer's payment or the fair market value of property transferred.
Payments by Individuals
A safe harbor was provided in Notice 2019-12 for individuals who have a portion of a charitable deduction disallowed due to the receipt of a SALT credit. Under the safe harbor, any disallowed portion of the charitable contribution deduction may be treated as the payment of SALT taxes for the purposes of deducting taxes under Code Sec. 164.
The new proposed regulations incorporate the safe harbor in Notice 2019-12. The safe harbor is allowed in the tax year the charitable payment is made, but only to the extent that the SALT credit is applied as provided under state or local law to offset the individual's SALT liability for the current or preceding tax year. Any unused credit may be carried forward as provided under state and local law.
Payments by Business Entities
The IRS also provided a safe harbor in Rev. Proc. 2019-12 that business entities may continue to deduct charitable contributions in exchange a SALT credit. A business entity may deduct the payments as ordinary and necessary business expenses under Code Sec. 162 if made for a business purpose.
The new proposed regulations incorporate the safe harbor in Rev. Proc. 2019-12. If a C corporation or specified pass-through entity makes the charitable payment in exchange for a SALT credit, it may deduct the payment as a business expense to the extent of any SALT credit received or expected to be received. In addition, the new proposal provides that if the charitable payment bears a direct relationship to the taxpayer's business then it may be deducted as a business expense rather than a charitable contribution regardless of whether the taxpayer receives or expects to receive a SALT credit.
Benefits Received from Third Party
If a taxpayer receives any goods, services, or other benefits from a charitable organization in consideration for a contribution, then the charitable deduction must be reduced by the value of those benefits. If the contribution exceeds the fair market value of the benefits received, then only the excess is a deductible as a charitable contribution.
The new proposed regulations clarify that this quid pro quo principal applies regardless of whether the party providing the goods, services, or other benefits is the charitable organization or not. A taxpayer will be treated under the proposal as receiving goods and services in consideration for the taxpayer's charitable contribution if, at the time the taxpayer makes the payment or transfer, the taxpayer receives or expects to receive goods or services in return.
Final Regulations Issued on CFC Related Person Rules, Active Trade or Business Exception
Final regulations provide rules on the attribution of ownership of stock or other interests, for determining whether a person is a related person with respect to a controlled foreign corporation (CFC) under the foreign base company sales income rules. The regulations also provide rules to determine whether a CFC receives rents in the active conduct of a trade or business, for determining the exception from foreign personal holding company income.
The regulations adopt without change, proposed regulations published on May 20, 2019 ( NPRM REG-125135-15).
Attribution of Ownership
The regulations provide specific rules for applying principles similar to those in the Code Sec. 958(b) constructive ownership rules when determining related person status under the foreign base company sales income rules. The determination of related person status is relevant for many purposes, including whether certain types of income can be characterized as subpart F foreign base company sales or service income.
A person is a related person with respect to a CFC if the person is:
an individual who controls the CFC,
an entity that controls or is controlled by the CFC, or
an entity that is controlled by the same person that controls the CFC.
Rules similar to those for determining stock ownership in Code Sec. 958 apply for purposes of determining whether a person is a related person. The regulations limit the application of the downward attribution rules in Code Sec. 318(a)(3), which apply by reference to the Code Sec. 958 stock ownership rules, and which attribute ownership downward from the owner of an entity to an entity. The downward attribution rules are applied regardless of the size of the ownership interest in a partnership, estate, or trust, but are applied to corporations based on a 50-percent or more ownership interest.
The regulations address concern that application of the downward attribution rules could inappropriately treat entities (including CFCs) that do not have significant relationships with each other as related persons. Accordingly, the regulations provide that the downward attribution rules of Code Sec. 318(a)(3) and Reg. §1.958-2(d) will not apply for purposes of determining related person status under the foreign base company sales income rules.
The change does not preclude a corporation, partnership, trust, or estate from being treated as controlled by the same person or persons that control the CFC under other rules that remain applicable for the related person rules.
Additionally, an anti-abuse rule is provided with respect to the option attribution rule in Code Sec. 318(a)(4). The option attribution rule in Code Sec. 318(a)(4) and Reg. §1.958-2(e) will not be applied to treat a person with an option as owning the stock or an equity interest for purposes of the related person rule if the principal purpose of using the option was to cause a person to be treated as a related person.
The regulations also incorporate a similar rule issued in section 7(d) of Notice 2007-9, 2007-1 CB 401. The rule applies if the principal purpose for the use of an option is to qualify dividends, interest, rents or royalties paid by a foreign corporation for the Code Sec. 954(c)(6) CFC look-through exception from foreign personal holding company income. The rule applies to tax years of CFCs beginning after December 31, 2006, and ending before November 19, 2019, and to tax years of U.S. shareholders in which or with which such tax years end.
Personal Holding Company Income
The regulations modify the foreign personal holding company rules for amounts paid or incurred by a CFC in connection with the CFC's rental income and the active rents exception. Rents are excluded from foreign personal holding company income if the rents are:
received from a person other than a related person, and
from the active conduct of a trade or business.
If rents are from leasing property as a result of marketing activities, there must be a substantial marketing organization in order to meet the active trade or business test. Under a safe harbor, an organization is substantial if active leasing expenses equal or exceed 25 percent of adjusted leasing profit. If the CFC receives rents from property it does not own, the substantiality of the organization is determined net of those rent payments.
The regulations extend the rule to apply to royalties in addition to rents. As a result, the substantiality of the organization is determined under the safe harbor net of the rents or royalties paid or incurred by the lessor CFC, for the right to use the property (or a component part of the property) that generated the rental income.
Applicability Date
The regulations generally apply to tax years of CFCs ending on or after November 19, 2019, and to tax years of U.S. shareholders in which or with which such tax years end. The regulations on the downward attribution rule, and the option anti-abuse rule for use of the option to treat a person as a related person with respect to a CFC, apply to tax years of CFCs ending on or after May 17, 2019, and to tax years of U.S. shareholders in which or with which such tax years end, with respect to amounts received or accrued by a CFC on or after May 17, 2019, to the extent the amounts are received or accrued in advance of the period to which such amounts are attributable with a principal purpose of avoiding application of the rules.
IRS Releases Final and Proposed BEAT Regulations
The IRS has issued final and proposed regulations implementing the base erosion and anti-abuse tax (BEAT) under Code Sec. 59A. The BEAT is a minimum tax that certain large corporations must pay on certain payments made to foreign related parties, and was added by the Tax Cuts and Jobs Act ( P.L. 115-97).
The final regulations adopt proposed rules ( REG-104259-18) published on December 21, 2018 (2018 proposed regulations), with certain modifications. The proposed regulations ( REG-112607-19) (2019 proposed regulations) provide rules under Code Secs. 59A and 6031 regarding certain aspects of the BEAT.
The 2018 proposed regulations provided guidance related to the mechanics of determining a taxpayer's BEAT liability, and addressed application of the BEAT to partnerships, banks, registered security dealers, and consolidated groups. The final BEAT regulations retain the basic approach and structure of the 2018 proposed regulations, with certain revisions.
The final regulations continue to be exclude from the denominator of the base erosion percentage Code Sec. 988 losses with respect to transactions with foreign related parties that are excluded from the numerator of the percentage. The final regulations also retain the add-back method for computing modified taxable income and the computation of base erosion minimum tax amount (BEMTA) on a taxpayer-by-taxpayer basis.
Among some of the more significant changes to the proposed rules, the final regulations:
adopt the "with-or-within" method to determine the gross receipts and the base erosion percentage of an aggregate group;
disregard transactions between parties if both parties were members of the aggregate group at the time of the transaction;
exclude the base erosion tax benefits and deductions attributable to the tax year of a member of an aggregate group that begins before January 1, 2018;
clarify that payments resulting in a reduction to determine gross income are not treated as base erosion payments;
require that the determination of whether a payment or accrual is a base erosion payment be made under general U.S. federal income tax law;
clarify the definition of a "base erosion payment," and generally exclude amounts transferred to, or exchanged with, a foreign related party in certain corporate nonrecognition transactions from that definition;
clarify the rules for determining the portion of U.S. branch interest paid to foreign related parties;
provide rules for the treatment of an interest expense determined under a U.S. tax treaty;
include additional detail on the documentation required to satisfy the service cost method (SCM) exception;
modify the total loss-absorbing capacity (TLAC) exception;
provide that the additional one percent add-on to the BEAT rate will not apply to a taxpayer that is part of an affiliated group with de minimis banking and securities dealer activities;
provide that Code Sec. 15 applies only to the change in tax rate set forth in Code Sec. 59A(b)(2) and should not apply to the change in tax rate included in Code Sec. 59A(b)(1)(A) for tax years beginning in calendar year 2018;
change the Qualified Derivative Payments (QDP) exception;
clarify the rules regarding how partnerships and their partners are treated for purposes of the BEAT; and
clarify the anti-abuse rule and certain rules applicable to insurance companies and consolidated groups.
Applicability Dates
The final regulations (other than the reporting requirements for QDPs) apply to tax years ending on or after December 17, 2018. However, taxpayers may apply these final regulations in their entirety for tax years ending before December 17, 2018. Taxpayers may also apply provisions matching Reg. §§1.59A-1 through 1.59A-9 in their entirety for all tax years ending on or before December 6, 2019. Taxpayers choosing to apply the proposed regulations must apply them consistently and cannot selectively choose which particular provisions to apply.
The related Code Sec. 6038A regulations apply to tax years beginning Monday, June 7, 2021. The related consolidated return regulations generally apply to tax years for which the original consolidated return is due (without extensions) after December 6, 2019.
2019 Proposed Regulations
The 2019 proposed regulations provide rules regarding relating to (1) how a taxpayer determines its aggregate group for purposes of determining gross receipts and the base erosion percentage; (2) an election to waive deductions; and (3) application of the BEAT to partnerships.
The 2019 proposed regulations generally apply to tax years beginning on or after the date that the final regulations are filed with the Federal Register. Certain rules, however, have specific applicability dates. In addition, taxpayers may rely on the rules in the proposed regulations in their entirety for tax years beginning after December 31, 2017, and before the final regulations are applicable.
Practitioner's Observations
Arlene Fitzpatrick, a Principal in the National Tax Department of Ernst & Young LLP, told Wolters Kluwer that "there are changes and new proposed rules in the package of final and proposed regulations that are helpful, though not all changes requested through the comment process were made. For example, the rules in the final regulations to exclude, in certain circumstances, from the definition of a base erosion payment amounts transferred to, or exchanged with, a foreign related party pursuant to a specified nonrecognition transaction are welcome. Furthermore, clarifying that a built-in loss recognized on a sale or transfer of property to a foreign related party is not in itself a deduction that causes the payment to be treated as a base erosion payment is helpful. The final regulations however, retain the internal dealings rule whereby a notional payment for purposes of attribution of profits under certain tax treaties may be taken into account for purposes of determining BEAT. Thus, although deductions from internal dealings would not be allowed under the Code or regulations, and only relevant under certain treaties (the regulations do not specify the treaties), the regulations provide such amounts are relevant for purposes of determining BEAT."
Final and Proposed Regulations Address Foreign Tax Credit
The IRS has issued highly anticipated final regulations on the significant changes made to the foreign tax credit rules by the Tax Cuts and Jobs Act (TCJA) ( P.L. 115-97). The final regulations retain the basic approach and structure of the 2018 proposed regulations ( NPRM REG-105600-18). The final regulations also eliminate deadwood, reflect statutory amendments made prior to TCJA, and update expense allocation rules not updated since 1988.
Also adopted are proposed regulations on overall foreign losses, published on June 25, 2012 ( NPRM REG-134935-11), and a U.S. taxpayer's obligation to notify the IRS of a foreign tax redetermination, published on November 7, 2007 ( NPRM REG-209020-86).
A separate set of 2019 proposed regulations were also issued ( NPRM REG-105495-19).
The final regulations make extensive changes to the rules on the determination of the foreign tax credit. Many of these changes were required to implement the TCJA, including the items discussed, below.
The final regulations provide details on how income is assigned and expenses are apportioned to the Code Sec. 951A global intangible low-taxed income (GILTI) and foreign branch foreign tax credit separate limitation categories added by TCJA.
The regulations provide that, for purposes of applying the expense allocation and apportionment rules, the portion of gross income related to foreign derived intangible income (FDII) or a GILTI inclusion that is offset by a Code Sec. 250 deduction is treated as exempt income. This means that fewer expenses will be allocated to the GILTI category, resulting in a higher foreign source taxable income, a higher foreign tax credit limitation, and a larger foreign tax credit offset with respect to GILTI income.
The regulations also address how the balance of foreign tax credit carryovers prior to the TCJA are allocated across new and existing separate categories. Under a default rule, foreign tax credit carryovers remain in the general category going forward. A taxpayer can elect to reconstruct the carryover regarding a foreign branch. The final regulations provide a simplified rule under which taxpayers can assign foreign tax credits to the foreign branch category proportionately, according to the ratio of foreign taxes paid or accrued by the taxpayer's branches to total foreign taxes paid or accrued by the taxpayer in that year.
The regulations modify the proposed rule for determining foreign branch income based on the U.S. tax-adjusted books and records of the foreign branch. The proposed regulations disregarded transfers of intellectual property (IP) between a foreign branch and its owner if the transfer would result in a deemed payment that reallocates income between the foreign branch category and the general branch category. The final regulations limit the rule to transactions that occurred after the date of the proposed regulations and include an exception for transitory ownership.
The regulations provide rules for the treatment of GILTI for purposes of the interest allocation rules. In general, a controlled foreign corporation (CFC) must allocate and apportion its interest expense among groups of income for purposes of determining tested income, subpart F income and other types of net foreign source income. A U.S. taxpayer must characterize the value of its CFC for allocating and apportioning its own interest expense. A CFC allocates and apportions its interest expense using either the modified gross income (MGI) method or the asset method. The U.S. taxpayer uses the same method to characterize the stock of its CFC. The regulations take into account gross tested income from a lower-tier CFC with respect to an upper-tier CFC for allocating the upper-tier CFC's interest expense when applying the MGI method.
Dividends, interest, rents and royalties (look-through payments) paid to a U.S. shareholder by a CFC were generally allocated to general category income to the extent that they were not treated as passive category income. Because this type of payment made directly by a U.S. shareholder is not included in the GILTI category, the regulations provide that the look-through payments are assigned either to the general category or the foreign branch category. The payments cannot be assigned to the GILTI category.
The final regulations also address certain potentially abusive borrowing arrangements involving loans by U.S. persons to foreign partnerships that artificially increase foreign source income and the foreign tax credit limitation without affecting U.S. taxable income. Under the regulations, the interest income attributable to borrowing through a partnership is allocated across the foreign tax credit separate limitation categories in the same manner as the associated interest expense.
Applicability of Final Regs
The final regulations related to statutory amendments made by the TCJA apply to tax years beginning after December 31, 2017. Regulations that contain both rules that relate to the TCJA and rules that do not relate to the TCJA generally apply to tax years that both (1) begin after December 31, 2017, and (2) end on or after December 4, 2018.
The regulations on the deemed paid credit under Code Sec. 960 apply to tax years that both begin after December 31, 2017, and end on or after December 4, 2018. The final OFL regulations apply to tax years on or after the date the regulations are filed in the Federal Register. The final foreign tax redetermination regulations apply to foreign tax redeterminations occurring in tax years ending on or after the date the regulations are filed in the Federal Register.
Proposed foreign tax credit regulations address changes made by the TCJA, and also respond to issues raised in the 2018 proposed regulations on the foreign tax credit ( NPRM REG-105600-18). The proposed regulations address:
the allocation and apportionment of deductions under Code Sec. 861 through Code Sec. 865;
the definition of "financial services income" under Code Sec. 904(d)(2)(D);
the allocation and apportionment of creditable foreign taxes;
the interaction of branch loss and dual consolidated loss recapture rules under Code Sec. 904(f) and Code Sec. 904(g);
the effect of Code Sec. 905(c) foreign tax redeterminations of foreign corporations on the high-tax exception in Code Sec. 954(b)(4) and the required notification and penalty provisions;
the definition of "personal holding company income" under Code Sec. 954; and
the application of the foreign tax credit limitation rule to consolidated groups.
Allocation and Apportionment
Under the general rule, a taxpayer may allocate research and experimentation (R&E) expenses to the foreign tax credit separate limitation categories under the sales method or the gross income method. The proposed regulations revise the sales method to provide that R&E expenses are only allocated to income that represents return on intellectual property. When applying these rules, gross intangible income does not include dividends or amounts included under subpart F, GILTI or Code Sec. 1293. As a result, none of a U.S. taxpayer's R&E expenses are allocated to the GILTI category. The proposed regulations eliminate the gross income method for purposes of allocating R&E expenses.
Stewardship expenses are related and allocable to dividends received or to be received from related corporations. The proposed regulations provide that stewardship expenses are allocated to subpart F and GILTI inclusions, to Code Sec. 78 dividends and all amounts included under the passive foreign investment company (PFIC) provisions.
Under the Code Sec. 818(f) allocation rules that apply to life insurance companies, expenses are generally apportioned ratably across all gross income. Under a new rule, the proposed regulations allocate expenses in a life-nonlife consolidated group solely among items of the insurance company that has reserves (separate entity method).
The final foreign tax credit limitations provide a matching rule for a U.S. partner that makes loans to a foreign partnership. Under the rule, the partner's gross interest income is apportioned between U.S. and foreign sources in each separate foreign tax credit limitation category based on the partner's interest expense apportionment ratios. The proposed regulations provide the same rule for loans from partnerships to U.S. partners (upstream partnership loans).
Redeterminations
Portions of the 2007 temporary regulations on foreign tax redeterminations ( T.D. 9362) are reproposed so that taxpayers can provide comments on the rules in light of the changes made by the TCJA. The proposed regulations address foreign tax redeterminations that affect the deemed paid credit under Code Sec. 960; procedural notification rules; and penalties for failure to notify the IRS of a foreign tax redetermination.
The proposed regulations require taxpayers to account for foreign tax redeterminations of foreign subsidiaries on an amended return that reflects the revised foreign taxes deemed paid under Code Sec. 960 and any changes to the taxpayer's U.S. tax liability. This reflects the repeal of the pooling mechanism to account for redeterminations of foreign taxes.
A transition rule provides that post-2017 redeterminations of pre-2018 foreign income taxes must be made by adjusting the foreign corporation's taxable income and earnings and profits and post-1986 undistributed earnings and income taxes in the pre-2018 year to which the redetermined foreign taxes relate. The proposed regulations also provide that the foreign tax redetermination rules cover situations in which the foreign tax redetermination affects whether or not the CFC qualifies for the high-tax exceptions under GILTI and subpart F.
Additional provisions in the proposed regulations:
modify the definition of a "financial services entity" by adopting a definition of "predominately engaged in the active conduct of a banking, insurance, finance, or similar business" and "income derived in the active conduct of a banking, insurance, finance, or similar business" that is generally consistent with Code Secs. 954(h), 1297(b)(2)(B), and 953(e);
provide more detailed guidance on the allocation and apportionment of foreign income taxes, and generalize the rules to apply to statutory and residual groupings;
provide a new ordering rule for overall foreign loss recapture that addresses additional income recognition under the branch loss recapture and dual consolidated loss recapture rules: the amounts are not taken into account for purposes of the ordering rules until Code Sec. 904(f)(3) amounts are determined;
clarify the rules that apply to jurisdictions that do not impose corporate income tax on CFCs until earnings are distributed. or where foreign tax is contingent on a future distributions, for purposes of the high-tax exception in Code Sec. 954(b)(4);
apply the principles for allocating and apportioning foreign income taxes for purposes of Code Sec. 965(g); and
update the Code Sec. 1502 regulations relating to the computation of the consolidated foreign tax credit to reflect changes in the law, and add new rules for the determining the source and separate category of the a consolidated NOL, as well as the portion of a consolidated net operating loss (CNOL) that is apportioned to a separate return year of a member.
Applicability of Proposed Regs
The proposed regulations are generally proposed to apply to tax years that end on or after the date the proposed regulations are filed in the Federal Register, with exceptions. For example, the rules for R&E expenses are proposed to apply to tax years beginning after December 31, 2019. However taxpayers on the sales method for tax years beginning after December 31, 2017, and before January 1, 2020, may rely on the proposed regulations if the rules are applied consistently. Thus, a taxpayer on the sales method for its tax year beginning in 2018 may rely on the proposed regulation, but must also apply the sales method (relying on the proposed regulation) for its tax year beginning in 2019.
WK: Were you surprised by anything in the final regs?
Martin Milner: The final regulations are generally consistent with the proposed regulations and do not include any major surprises. The changes and clarifications that are in the final regulations are largely helpful. As would be expected, most of the new provisions are in the proposed portion of the package.
WK: With the proposed regs are there areas that you can see may result in pushback? If so why?
Martin Milner: The business community is likely to comment on the proposal to apportion stewardship expenses to dividends, subpart F income and GILTI (including IRC Section 78 gross-ups) because many had hoped that stewardship expenses would not be apportioned to GILTI.
WK: How did you feel about the R&E Expense Apportionment changes?
Martin Milner: The mandatory sales-based apportionment of R&E expenses to all gross intangible income related to the relevant product SIC code will be complicated in practice. However, it is helpful that the proposed rules specifically exclude dividends, subpart F income and GILTI.
Partner Tax Basis Capital Reporting Not Required Until 2020 Partnership Tax Years
The IRS has released guidance that provides that the requirement to report partners' shares of partnership capital on the tax basis method will not be effective for 2019 partnership tax years, but will first apply to 2020 partnership tax years.
2019 Reporting
For 2019, partnerships and other persons must report partner capital accounts consistent with the reporting requirements in the 2018 forms and instructions, including the requirement to report negative tax basis capital accounts on a partner-by-partner basis.
Section 704(c) Gain or Loss
As a clarification, the notice also defines the term "partner's share of net unrecognized Code Sec. 704(c) gain or loss," which must be reported by partnerships and other persons in 2019. Further, the notice exempts publicly traded partnerships from the requirement to report their partners' shares of net unrecognized Code Sec. 704(c) gain or loss until further notice. Solely for purposes of completing the 2019 Forms 1065, Schedule K-1, Item N, and 8865, Schedule K-1, Item G, the notice defines a partner's share of "net unrecognized Code Sec. 704(c) gain or loss" as the partner's share of the net (meaning aggregate or sum) of all unrecognized gains or losses under Code Sec. 704(c) in partnership property, including Code Sec. 704(c) gains and losses arising from revaluations of partnership property.
Section 465 At-Risk Activities
The notice provides that the requirement added by the draft instructions for 2019 for partnerships to report to partners information about separate Code Sec. 465 at-risk activities will not be effective until 2020. The draft of the instructions for the 2019 Form 1065, Schedule K-1, released October 29, 2019, included a new paragraph at page 12, At-Risk Limitations, At-Risk Activity Reporting Requirements, that would expressly require partnerships or other persons that have items of income, loss, or deduction reported on the Schedule K-1 from more than one activity that may be subject to limitation under Code Sec. 465 at the partner level to report certain additional information separately for each activity on an attachment to a partner's Schedule K-1. The new paragraph would require the partnership to identify the at-risk activity, the items of income, loss, or deduction for the activity, other items of income, loss, or deduction, partnership liabilities, and any other information that relates to the activity, such as distributions and partner loans. This requirement in the draft instructions for the 2019 Form 1065 is in addition to long-standing at-risk reporting requirements included in the instructions to the Form 1065.
Penalty Relief
Taxpayers who follow the provisions of the notice will not be subject to any penalty, including a penalty under Code Sec. 6722 for failure to furnish correct payee statements, under Code Sec. 6698 for failure to file a partnership return that shows required information, and under Code Sec. 6038 for failure to furnish information required on a Schedule K-1 (Form 8865).
Final Regulations on Calculation of UBTI Issued
The IRS has released final regulations that present guidance on how certain organizations that provide employee benefits must calculate unrelated business taxable income (UBTI) under Code Sec. 512(a).
Organizations that are otherwise exempt from tax under Code Sec. 501(a) are subject to tax on their unrelated business taxable income (UBTI) under Code Sec. 511(a). Code Sec. 512(a) defines UBTI of exempt organizations and provides special rules for calculating UBTI for organizations described in Code Sec. 501(c)(7) (social and recreational clubs), voluntary employees' beneficiary associations (VEBAs) described in Code Sec. 501(c)(9) and supplemental unemployment benefit trusts (SUBs) described in Code Sec. 501(c)(17).
Covered Entity
"Covered entity" describes VEBAs and SUBs subject to the UBTI computation rules under Code Sec. 512(a)(3). A corporation is treated as having exempt function income for a taxable year only if it files a consolidated return with the organization described in Code Sec. 501(c)(7), (9), or (17). These final regulations add a clause to clarify that the term "covered entity" includes a corporation described in Code Sec. 501(c)(2) to the extent provided in Code Sec. 512(a)(3)(C).
Nonrecognition of Gain
If a property used directly in the performance of the exempt function of a covered entity is sold by that covered entity, and other property is subsequently purchased and used by the covered entity directly in the performance of its exempt function—at any point within a four-year period beginning one year before the date of the sale and ending three years after the date of sale—gain, if any, from the sale is recognized only to the extent that the sales price of the old property exceeds the covered entity's cost of purchasing the other property.
Limitation on Amounts Set Aside for Exempt Purposes
The total amount of investment income earned during the year should be considered when calculating whether an excess exists at the end of the year. Any investment income a covered entity earns during the taxable year is subject to unrelated business income tax (UBIT) to the extent the covered entity's year-end assets exceed the account limit.
The final regulations apply to tax years beginning on or after December 10, 2019.
Final Rules Adopted on Changes to Estate Tax Exclusion Amount
The IRS has issued Reg. §20.2010-1(c) to address the effect of the temporary increase in the basic exclusion amount (BEA) used in computing estate and gift taxes. In addition, Reg. §20.2010-1(e)(3) is amended to reflect the increased BEA for years 2018-2025 ($10 million, as adjusted for inflation). Further, the IRS has confirmed that taxpayers taking advantage of the increased BEA in effect from 2018 to 2025 will not be adversely affected after 2025 when the exclusion amount is set to decrease to pre-2018 levels.
The regulations apply to estates of decedents dying on and after November 26, 2019.
Special Rule for Post-2025 Decedents
Reg. §20.2010-1(c) provides a special rule in cases where the portion of the credit against the estate tax that is based on the BEA is less than the sum of the credit amounts attributable to the BEA allowable in computing gift tax payable within the meaning of Code Sec. 2001(b)(2). In that situation, the portion of the credit against the net tentative estate tax that is attributable to the BEA is based upon the greater of those two credit amounts.
Inflation-Adjusted Amounts and DSUE Amount
Because the term "BEA" includes the exclusion amount, as adjusted for inflation, the examples in the regulations reflect hypothetical inflated adjusted BEAs. Reg. §20.2010-1(c)(2)(ii), Example 2, illustrates the application of the special rule based on gifts actually made, and would be inapplicable to a decedent who did not make gifts in excess of the date of death BEA, as adjusted for inflation.
Reg. §20.2010-1(c)(2)(iii) and (iv), Examples 3 and 4, illustrate that if a spouse dies during the increased BEA period, and the deceased spouse's executor makes the portability election, the surviving spouse's applicable exclusion amount includes the full amount of the deceased spousal unused exclusion (DSUE) amount based on the deceased spouse's increased BEA. The DSUE amount is available to reduce the surviving spouse's transfer tax liability regardless of when transfers are made.
BEA Calculations
The final rules explain how to determine the extent to which a credit allowable in computing gift tax payable is based solely on the BEA. Reg. §20.2010-1(c)(2)(iv), Example 4, addresses the application of the DSUE ordering rule, as well as the computation of the credit based solely on the BEA in a calendar period in which the transfer exhausts the remaining DSUE amount with the result that the BEA is also allowable.
TIGTA Recommends Improvements to Consistent Suitability Checks for Participation in IRS Programs
The Treasury Inspector General for Tax Administration (TIGTA) has released a report on suitability checks for participation in IRS programs. TIGTA initiated this audit to assess the effectiveness of IRS processes to ensure the suitability of applicants seeking to participate in IRS programs and to follow up on IRS planned corrective actions to address prior TIGTA recommendations.
TIGTA Final Audit Report
Suitability Checks
The IRS's suitability checks for applicants to the Acceptance Agent, Enrolled Agent, and e-File Provider Programs generally ensured that only reputable individuals were accepted in the programs during fiscal year 2018. Further, the IRS's continuous suitability checks also ensured that individuals accepted in the programs prior to the initial suitability checks had not engaged in criminal activity warranting removal from the program. TIGTA also identified that when the Federal Bureau of Investigation reported a criminal history for an applicant, the adjudication process was inconsistent depending on the program to which the individual was applying. Finally, the IRS did not take sufficient actions to address the fraudulent submission of fingerprint cards by some applicants to pass their background investigations.
TIGTA Recommendations
TIGTA recommended that the IRS:
assess the risk to tax administration of performing inconsistent initial and continuous suitability checks on individuals seeking to participate or enrolled in the e-File Provider, Acceptance Agent, and Enrolled Agent Programs;
assess the risk of the e-File Provider Program's use of decision matrices to adjudicate an applicant's criminal history that are inconsistent with the matrices used by the Acceptance Agent and Enrolled Agent Programs; and
work with the Federal Bureau of Investigation to identify additional individuals who may have submitted fingerprint cards that match the fingerprints of another individual.
The IRS agreed with all the recommendations.
How do I: Get an extension of time to change a method of accounting?
A taxpayer changing its method of accounting must either request advance IRS consent or apply for automatic IRS consent on Form 3115, Application for Change in Accounting Method, to make the change. Automatic consent is more favorable because the taxpayer can request the change on its return filed after the year it makes the change. A taxpayer requesting automatic consent must submit Form 3115 by the due date of the return for the year of the change. Recent IRS actions indicate that a taxpayer who fails to make a timely request for a change of accounting method may qualify for an extension of time to request the change.
In 2013, the IRS issued "repair regs" that determine whether a taxpayer must capitalize or can deduct its costs related to the use of tangible property. To take advantage of the treatment provided in the regs, taxpayers often had to change their accounting methods. The IRS provided automatic consent for taxpayers to change their methods of accounting to comply with the repair regs.
Regulatory Elections
If a taxpayer fails to make a "regulatory" election on time, the IRS has discretion to grant an extension of time for making the election. A regulatory election is whose deadline is established by the IRS in regulations or other guidance, in contrast to an election whose deadline is set by statute. A taxpayer must submit a private letter request asking for an IRS ruling that grants relief. The IRS will grant relief only if it is satisfied that the taxpayer acted reasonably and in good faith when it failed to make a timely election, and that granting an extension will not prejudice the government.
Extensions Granted
The IRS has granted extensions of time to several taxpayers who missed the deadline for requesting automatic IRS consent to change a method of accounting under the repair regs. The IRS gave the taxpayer an additional 60 days (after the IRS issued the favorable letter ruling) to make the election.
In one sample ruling request, the taxpayer (a corporation) was required to submit the original of Form 3115 with its timely income tax return filed for the year of change, and to provide a copy of the Form 3115 to the IRS in Ogden, Utah. The taxpayer's return preparer timely e-filed the taxpayer's Form 1120, prepared Form 3115, and submitted a copy of the form to Ogden. However, the preparer inadvertently failed to scan the Form 3115 and include it with the taxpayer's return. The preparer discovered the omission and the taxpayer applied for an extension. The IRS granted the taxpayer an additional 60 days to elect the change of accounting method permitted under the repair regs.
Taxpayer protections, IRS oversight bills advance in Congress
Responding to growing concerns over the scope of tax-related identity theft, the House has approved legislation to give victims more information about the crime. The House also took up a bill expanding disclosure of taxpayer information in cases involving missing children and the Ways and Means Committee approved a bill impacting disclosures by exempt organizations.
Stolen identity refund fraud
Tax-related identity theft occurs when a criminal uses the personal identification of another to obtain a fraudulent refund. According to the IRS and the Treasury Inspector General for Tax Administration (TIGTA), tax-related identity theft continues to grow despite efforts to uncover and apprehend criminals. In 2014, the IRS estimated that it prevented the issuance of nearly $25 billion in fraudulent refunds. However, criminals obtained more than $5 billion in fraudulent refunds.
More often than not, individuals are unware they have been victims until they file their return and discover that a return has already been filed by an identity thief. In some cases, the IRS may send a letter to the taxpayer reporting that the agency identified a suspicious return using the individual's personal information.
On May 19, the House approved the Stolen Identity Refund Fraud Prevention Act of 2016 (HR 3832). HR 3832 would require the IRS to notify victims of tax-related identity theft as soon as practicable that his or her personal information was used without authorization. The IRS also would be required to notify victims of tax-related identity theft of any criminal changes brought against the alleged identity thief.
Additionally, the bill would create a centralized point of contact for victims of identity theft. The centralized point of contact may be a team or subset of specially trained employees who can work across functions to resolve problems for the victim and who is accountable for handling the case to completion. The makeup of the team may change as required to meet IRS needs, but the procedures must ensure continuity of records and case history and may require notice to the taxpayer in appropriate instances.
The bill also would make willful misappropriation of a taxpayer's identity for the purpose of making any return a felony. Under the bill, this offense would be punishable by a fine of up to $250,000 ($500,000 for a corporation), imprisonment for up to five years, or both, plus prosecution costs.
The House approved the bipartisan Recovering Missing Children Bill (HR 3209) on May 10. The bill amends the Tax Code to grant law enforcement access to taxpayer information while investigating missing and exploited children. Under Code Sec. 6103, return information is confidential.
Exempt organizations
The Preventing IRS Abuse and Protecting Free Speech Bill (HR 5053) limits the contributor information that must be reported by a Code Sec. 501(c) on its annual return. Generally, the IRS may not require an exempt organization to report the name, address, or other identifying information of any contributor to the organization with respect to any contribution, grant, bequest, devise, or gift of money or property, regardless of amount. The bill is awaiting action by the full House after having been approved by the Ways and Means Committee.
If you have any questions about these or other pending bills, please contact our office.
Don't overlook new-for-2016 enhancements to certain tax incentives
Passage of the "Tax Extenders" undeniably provided one of the major headlines – and tax benefits – to come out of the Protecting Americans from Tax Hikes Act of 2015 (PATH Act), signed into law on December 18, 2015. Although these tax extenders (over 50 of them in all) were largely made retroactive to January 1, 2015, valuable enhancements to some of these tax benefits were not made retroactive. Rather, these enhancements were made effective only starting January 1, 2016. As a result, individuals and businesses alike should treat these enhancements as brand-new tax breaks, taking a close look at whether one or several of them may apply. Here's a list to consider as 2016 tax planning gets underway now that tax filing-season has ended.
Passage of the "Tax Extenders" undeniably provided one of the major headlines – and tax benefits – to come out of the Protecting Americans from Tax Hikes Act of 2015 (PATH Act), signed into law on December 18, 2015. Although these tax extenders (over 50 of them in all) were largely made retroactive to January 1, 2015, valuable enhancements to some of these tax benefits were not made retroactive. Rather, these enhancements were made effective only starting January 1, 2016. As a result, individuals and businesses alike should treat these enhancements as brand-new tax breaks, taking a close look at whether one or several of them may apply. Here's a list to consider as 2016 tax planning gets underway now that tax filing-season has ended:
Section 179 expensing. The PATH Act permanently extended the Code Section 179 dollar of investment limitations at the higher $500,000 and $2 million, levels, which are adjusted for inflation for tax years beginning after 2015 (it is $500,000 and $2,010,000 for 2016). In addition, starting only in 2016, the $250,000 limitation on the amount of section 179 property that can be attributable to qualified real property has been eliminated. Further, for tax years beginning after 2015, the Code Section 179 expense deduction is now allowed for air conditioning and heating units.
Bonus depreciation. In addition to the big news that the PATH Act extended Code Section 168(k) bonus depreciation to apply to most qualifying property placed in service before January 1, 2020, it made a number of modifications, including:
replacement of the bonus allowance for qualified leasehold improvement property with a bonus allowance for additions and improvements to the interior of any nonresidential real property, effective for property placed in service after 2015; and
allowance to farmers of a 50 percent deduction in place of bonus depreciation on certain trees, vines, and plants in the year of planting or grafting rather than the placed-in-service year, effective for planting and grafting after 2015.
Section 181 expensing. Special Section 181 expensing for qualified film and television productions is extended for two years to apply to qualified film and television productions commencing before January 1, 2017. However, the expensing rule is also expanded to apply to qualified live theatrical productions commencing after December 31, 2015.
WOTC. The Work Opportunity Tax Credit (WOTC) has been extended five years through December 31, 2019. In addition, the credit has been expanded and made available to employers who hire individuals who are qualified long-term unemployment recipients who begin work for the employer after December 31, 2015.
Research credit. The PATH Act permanently extended the research credit that applies to amounts paid or incurred after December 31, 2014. However, a new allowance of the research credit against alternative minimum tax liability applies to credits determined for tax years beginning after December 31, 2015. In addition, a new payroll tax credit associated with the research credit applies only to tax years beginning after December 31, 2015 (Act Sec. 121(d) (3) of the PATH Act).
Military differential pay. The PATH Act extended the employer tax credit for differential wage payments made to qualified employees on active military duty has been made permanent and applies to payments made after December 31, 2014. Effective only for tax years beginning after December 31, 2015, however, the credit may be claimed by all employers regardless of the average number of individuals employed during the tax year. The credit is also no longer limited to eligible small business employers with less than 50 employees.
Teachers' classroom expense deduction. The PATH Act permanently extended the above-the-line deduction for elementary and secondary school teachers' classroom expenses. Additionally, for tax years after 2015, the Act includes "professional development expenses" within the scope of the deduction. These expenses include courses related to the curriculum in which the educator provides instruction.
Nonbusiness energy property credit. The PATH Act extended the nonrefundable nonbusiness energy property credit allowed to individuals under Code Sec. 25C for two years, making it available for qualified energy improvements and property placed in service before January 1, 2017. For property placed in service after December 31, 2015, the standards for energy efficient building envelope components are modified to meet new conservation criteria.
If you have any questions about these new "extenders," please contact our office.
How do I? Set up a like-kind exchange
Under Code Sec. 1031, a taxpayer can make a tax-free exchange of property held for productive use in a trade or business or for investment. The exchange must be made for other property that the taxpayer will continue to use in a trade or business or for investment. Ordinarily, the exchange is made directly with another taxpayer who holds like-kind property. For example, an investor in real estate may exchange a building with another person who also owns real estate for use in a trade or business or for investment.
Another way to take advantage of Code Sec. 1031 is to make a deferred like-kind exchange, using a third person to facilitate the exchange. This can be advantageous when the taxpayer cannot find another holder of like-kind property to make a direct exchange with. The taxpayer identifies a third person to act as a qualified intermediary (QI) and enters into a legal agreement with the QI. The QI is not treated as the agent of the taxpayer. The QI acquires from the taxpayer the property that the taxpayer is relinquishing, and sells the property to another person identified by the taxpayer. As part of the transaction, the QI acquires legal title to the property and transfers it to the person buying the property.
The agreement between the taxpayer and the QI must provide that the taxpayer has no right to the proceeds received by the QI. Otherwise, the taxpayer would be in actual or constructive receipt of the proceeds. If this occurred, the exchange would not be tax-free.
To complete the deferred like-kind exchange, the taxpayer will identify other like-kind property that it wishes to acquire, perhaps from a fourth person. The QI will use the proceeds from the original sale to purchase the property sought by the taxpayer, again acquiring legal title to the property. Finally, the QI will transfer the acquired property to the taxpayer. The taxpayer's transfer of the relinquished property and acquisition of the replacement property qualify as a like-kind exchange.
How do I? Arrange an installment payment agreement with the IRS?
The IRS always urges taxpayers to pay their current tax liabilities when due, to avoid interest and penalties. Taxpayers who can't pay the full amount are urged to pay as much as they can, for the same reason. But some taxpayers cannot pay their full tax liability by the normal April 15 deadline (April 18th in 2016 because of the intersection of a weekend and a District of Columbia holiday).
One alternative is to enter into an installment payment agreement with the IRS, where taxpayers agree in writing to make monthly payments to the IRS and to reduce their tax liability to zero over a reasonable period of time. The IRS may also agree to an installment payment arrangement for back taxes. Penalties and interest may continue to accrue, although the IRS may reduce the penalties. While the IRS is authorized to enter into a partial payment installment agreement for a portion of the taxpayer's liability, the agency has been reluctant to do this.
Taxpayers who cannot pay the tax liability reported on their current income tax return should submit Form 9465, Installment Agreement Request, to the IRS, to request a monthly installment plan. A taxpayer who owes more than $50,000 should provide Form 433-F, Collection Information Statement, along with the request. Taxpayers can enter into different types of agreements, including:
A traditional agreement, where they agree to make their monthly payment by check, money order, or credit card;
A direct debit installment agreement, to make automatic payments from a bank account; or
A payroll deduction agreement, with payments made by the employer from a paycheck.
The IRS charges a user fee for entering into an agreement: $120 for a traditional agreement; or $52 for a direct debit agreement. Qualifying low-income taxpayers pay a fee of $43, regardless of the type of agreement. If the agreement is restructured (because of a change in the taxpayer's financial condition, for example), or if the IRS terminates the agreement and then agrees to reinstate it, the IRS will charge a fee of $50.
Different agreements
The IRS's procedures include different kinds of agreements, depending on the taxpayer's circumstances:
Taxpayers can use Form 9465 to apply for a streamlined agreement. The taxpayer must owe $50,000 or less and must pay all their taxes within 72 months or by the expiration of the collection statute of limitations (generally 10 years).
Instead of using Form 9465, taxpayers can apply for an online payment agreement, provided the taxpayer owes $50,000 or less in taxes, interest and penalties, or provided the taxpayer owns a business and owes $25,000 or less in total. A taxpayer cannot apply online for this agreement if the taxpayer owes more than $50,000.
Taxpayers who owe $10,000 or less (without interest or penalties) can enter into a guaranteed installment agreement if the taxpayer agrees to pay all taxes within three years. The taxpayer must have filed all returns and paid all taxes due for the past five years, and cannot have entered into an installment agreement in the same period.
A taxpayer who can make full payment within 120 days should not use Form 9465 but should instead call the IRS phone line to make arrangements. There is no user fee.
FAQ: What is the self-rental rule?
Under Code Sec. 469, passive losses can only be used to offset passive income. Taxpayers who have losses from a passive activity cannot use losses from a passive activity to offset nonpassive income, such as wages. A passive activity generally is an activity in which a taxpayer does not "materially participate." Passive losses that cannot be deducted must be carried over to a future year, where they can offset newly generated passive income.
Taxpayers with excess passive losses may seek to generate additional passive income by converting nonpassive income into passive income. The regulations under Code Sec. 469 (Reg. §1.469-2(f)(6)) include a "self-rental rule" to prevent taxpayers from creating artificial passive activity income that they could use to offset their passive losses.
Ordinarily, rental income is treated as passive income. However, the self-rental rule provides that income from a taxpayer's rental activity from an item of property, is treated as not being from a passive activity if the property is rented for use in a trade or business activity in which the taxpayer materially participates. Income that is recharacterized as nonpassive income cannot offset passive losses.
An example of the self-rental rule was addressed in Williams, CA-5, 2016-1 USTC ¶50,173. In Williams, the taxpayer owned a C corporation and materially participated in the corporation's trade or business. The taxpayer also owned an S corporation that rented real estate to the C corporation. The taxpayer did not materially participate in the rental activity. The rental activity generated income, which the taxpayer treated as passive income and used to offset passive losses from other entities.
The court concluded that the self-rental rule applied to the S corporation's rental of the real property. The taxpayer, the owner of the S corporation, materially participated in the business of the C corporation that rented the property. As a result, the income generated by the rental activity had to be recharacterized as nonpassive income under the self-rental rule, and could not be used to offset the taxpayer's passive losses from other activities.
How Do I? Elect to be taxed as an S corporation?
An S election is made by a small business corporation with the consent of its shareholders. Both the corporation and its shareholders must precisely follow the S election requirements or the election will not be valid.
Qualified corporation. A corporation qualifies as a small business corporation for S corporation purposes if the following requirements are met, regardless of the corporation's size or earnings:
The corporation is a qualifying domestic corporation;
It is not an ineligible corporation;
It has no more than 100 shareholders;
All shareholders are individuals, estates, certain trusts or qualifying tax-exempt entities;
No shareholder is a nonresident alien; and
Only one class of stock is outstanding.
Form 2553. To make an S election, a qualified small business corporation files Form 2553, Election by a Small Business Corporation. The form must be signed by an authorized corporate officer and accompanied by the appropriate shareholder consents or with a written statement of consent signed by each shareholder. These items are filed with either the Internal Revenue Service Center in Cincinnati, Ohio, or in Ogden, Utah, depending on where the corporation's principal business, office or agency is located. The form has instructions so it is a good idea to follow those when filling out the form.
Shareholder consent. All shareholders of the corporation must indicate their consent to the S election. The consent may be provided using Form 2553 or an attachment to it.
Deadlines. The election has to be made on or before the 15 th day of the third month of the corporation's tax year in order for the S election to be effective beginning with that year. If the proper election is not made by this day the election does not become effective until the following year.
Once an S election is in effect, new shareholders need not consent to keep the election effective. The election remains valid, although a new majority shareholder may revoke the election after acquiring the shares.
FAQ... When do I need to file IRS Form 8938, Statement of Specified Foreign Financial Assets?
The Foreign Account Tax Compliance Act (FATCA), enacted in 2010, requires certain U.S. taxpayers to report their interests in specified foreign financial assets. The reporting requirement may apply if the assets have an aggregate value exceeding certain thresholds. The IRS has released Form 8938, Statement of Specified Foreign Financial Assets, for this reporting requirement under FATCA.
The Foreign Account Tax Compliance Act (FATCA), enacted in 2010, requires certain U.S. taxpayers to report their interests in specified foreign financial assets. The reporting requirement may apply if the assets have an aggregate value exceeding certain thresholds. The IRS has released Form 8938, Statement of Specified Foreign Financial Assets, for this reporting requirement under FATCA.
For now, only specified individuals are required to file Form 8938, but specified U.S. entities will eventually also have to file the form. Taxpayers who do not file a federal income tax return for the year do not have to File Form 8938, even if the value of their foreign assets exceeds the normal reporting threshold.
Individuals who have to file Form 8938 include U.S. citizens, resident aliens for any part of the year, and nonresident aliens living in Puerto Rico or American Samoa.
Reporting applies to specified foreign financial assets. Specified foreign financial assets include:
A financial account maintained by a foreign financial institution;
Other foreign financial assets, such as stock or securities issued by a non-U.S. person, or an interest in a foreign entity.
The aggregate value of the individual's specified foreign financial assets must exceed specified reporting thresholds, as follows:
Unmarried U.S. taxpayers, and married U.S. taxpayers filing a separate return – more than $50,000 on the last day of the year, or more than $75,000 at any time during the year;
U.S. married taxpayers filing a joint return – more than $100,000 on the last day of the year, or more than $150,000 at any time during the year; or
Taxpayers living abroad: if filing a joint return, more than $400,000 on the last day of the year, or more than $600,000 during the year; other taxpayers, more than $200,000 on the last day of the year, or more than $300,000 at any time during the year.
Taxpayers who report assets on other forms, such as Form 3520, do not have to report the asset on Form 8938, but must use Form 8938 to identify other forms on which they report.
Reporting applies for tax years beginning after March 18, 2010, the date that FATCA was enacted. Most taxpayers, such as those who report their taxes for the calendar year, must start filing Form 8938 with their 2011 income tax return.
If you have any questions about Form 8938, please contact our office.
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text:
package org.woodwardbernsteinprotocol.message;

import junit.framework.TestCase;
import org.woodwardbernsteinprotocol.identity.IdentityName;

import java.io.ByteArrayInputStream;
import java.io.ByteArrayOutputStream;
import java.util.Vector;
/**
 * Created by dmcennis.
 * Licensed under the Apache 2.0 license.  See license.txt
 */
public class TipTest extends TestCase {

    public void testTransmitContentSimple() throws Exception {
        Tip tip = new Tip();
        tip.setContent("A tip");
        tip.setIdentity(new IdentityName("Daniel"));
        ByteArrayOutputStream output = new ByteArrayOutputStream();
        tip.transmit(output);
    }

    public void testParseContentSimple() throws Exception {
        Tip tip = new Tip();
        tip.setContent("A tip");
        IdentityName name = new IdentityName("Daniel");
        tip.setIdentity(name);
        ByteArrayOutputStream output = new ByteArrayOutputStream();
        tip.transmit(output);
        ByteArrayInputStream input = new ByteArrayInputStream(output.toByteArray());
        Tip in = (Tip)MessageFactory.parse(input);
        assertEquals(in.getContent(),"A tip");
        assertEquals(tip.getIdentity(),name);
    }

    public void testTransmitContentComplex() throws Exception {
        Tip tip = new Tip();
        tip.setContent("A tip");
        Tip child = new Tip();
        child.setContent("Child");
        child.setIdentity(new IdentityName("WhiteTigerPup"));
        tip.setIdentity(new IdentityName("Daniel"));
        tip.addChild(child);
        ByteArrayOutputStream output = new ByteArrayOutputStream();
        tip.transmit(output);
    }

    public void testParseContentComplex() throws Exception {
        Tip tip = new Tip();
        tip.setContent("A tip");
        IdentityName name = new IdentityName("Daniel");
        tip.setIdentity(name);
        Tip child = new Tip();
        child.setContent("Child");
        IdentityName childName = new IdentityName("WhiteTigerPup");
        child.setIdentity(childName);
        tip.addChild(child);
        ByteArrayOutputStream output = new ByteArrayOutputStream();
        tip.transmit(output);
        ByteArrayInputStream input = new ByteArrayInputStream(output.toByteArray());
        Tip in = (Tip)MessageFactory.parse(input);
        assertEquals("A tip",in.getContent());
        assertEquals(name,tip.getIdentity());
        assertEquals(1,tip.getChildren().size());
        MessageInterface m = tip.getChildren().get(0);
        assertTrue(m instanceof Tip);
        Tip t = (Tip)m;
        assertEquals("Child",t.getContent());
        assertEquals(childName,t.getIdentity());
    }

    public void testGetContent() throws Exception {
        Tip tip = new Tip();
        tip.setContent("message");
        tip.setIdentity(new IdentityName("Daniel"));
        assertEquals("message",tip.getContent());
    }

    public void testGetChildren() throws Exception {
        Tip tip = new Tip("message",new IdentityName("Daniel"));
        tip.addChild(new Tip("Child1",new IdentityName("ChildA")));
        tip.addChild(new Tip("Child2",new IdentityName("ChildB")));
        assertEquals(2,tip.getChildren().size());
        assertEquals("Child1",tip.getChildren().get(0).getContent());
        assertEquals("Child2",tip.getChildren().get(1).getContent());
    }

    public void testGetIdentity() throws Exception {
        Tip tip = new Tip("Message",new IdentityName("Daniel"));
        assertEquals(new IdentityName("Daniel"),tip.getIdentity());
    }

    public void testGetContext() throws Exception {
        Tip tip = new Tip("Message",new IdentityName("Daniel"));
        assertEquals("Message",tip.getContent());
    }

    public void testSetID() throws Exception {
        Tip tip = new Tip("Message",new IdentityName("Other"));
        tip.setIdentity(new IdentityName("Daniel"));
        assertEquals(new IdentityName("Daniel"),tip.getIdentity());
    }

    public void testAddChild() throws Exception {
        Tip tip = new Tip("Message",new IdentityName("Daniel"));
        Tip child = new Tip("Next Message", new IdentityName("McEnnis"));
        tip.addChild(child);
        assertEquals(1,tip.getChildren().size());
        assertEquals(child.getContent(),tip.getChildren().get(0).getContent());
        assertEquals(child.getIdentity(),tip.getChildren().get(0).getIdentity());
    }

    public void testAddAllChildren() throws Exception{
        Tip tip = new Tip("Message",new IdentityName("Daniel"));
        Vector<MessageInterface> vector  = new Vector<MessageInterface>();
        vector.add(new Tip("Message1",new IdentityName("Child1")));
        vector.add(new Tip("Message2",new IdentityName("Child2")));
        tip.addAllChildren(vector);
        assertEquals(2,tip.getChildren().size());
        assertEquals("Message1",tip.getChildren().get(0).getContent());
        assertEquals("Message2",tip.getChildren().get(1).getContent());

    }
}

redpajama_set_name: RedPajamaGithub


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text:
Ghostpoet: Shedding Skin
by Brady Frost
in 89, August 2015
"I think we're in a time now where genre is irrelevant." It's in unusual surroundings that I meet Ghostpoet backstage, before he opens this year's Tramlines. Greeted by him backstage in a wood cabin that wouldn't go amiss at Center Parcs, the room is clad in a rainforest theme, behind him a parrot backdrop and stuffed toy tigers nearby. "Not the theme I would have chosen," he notes. While the room may be flamboyant, the man occupying it certainly isn't, looking relaxed and every bit the part of a professional artist as he prepares to address the Sheffield crowd in a couple of hours. 2015 has been a good year for Obaro Ejimiwe. His third album, Shedding Skin, has been released to critical acclaim and, with a summer on the festival circuit followed by a tour later in the year, it should a busy year too. Taking time out from his schedule, we caught up with the 32-year-old to talk about playing festivals, the frustration of being pigeonholed as an artist and leftfield weirdness. You're the opening act for Tramlines on the new Main Stage. Do you find yourself changing your approach to festivals compared to gigs? Slightly, just through advice. I realised that at festivals you can't force the issue. With your own gigs, you're under the impression that most of the people in attendance know your stuff, so you can push it a bit more and expect people to get involved. But with festivals, it's so much passing traffic. You don't know what their mind state is, especially when you're the first one on. You don't know, so you can't force the issue, so I just have to let things play how they want to, but it's about being a bit more relaxed mentally about it. Have you found the reception to Shedding Skin different to your previous efforts? I don't really see it as a big change. It's been really good to make a record, which I wanted to be a bit more immediate for the listener, a bit more clearer in terms of where the tracks were heading. I can do leftfield weirdness if I wanted to, but I thought, let's make it a bit more central, but at the same time still interesting and 'myself'. It's nice that people have been getting into it and the reception's been pretty good. I can't complain with that. The artwork of Shedding Skin is great. I found out it was your own skin, and all the artwork is your own skin biopsies. Do you feel it matches the vibe of the album? As much as you want to have the music link with the artwork. I look at them as two separate things in a sense, that I wanted the artwork to be influenced by the music and the title more so, but I just went with my gut in terms of what I felt would work design-wise. It was led by the title and I just wanted to make it interesting, rather than a mugshot or a blatant representation of the title. I'm pleased with it. Your artwork was inspired by science. Do you plan to work more scientifically in the future? I've actually done another project called Body Of Songs, which was a production company deciding that they want to produce an album where the artist would be influenced by different body parts. So I chose the liver and made this song that was influenced by that. It's an album that's featuring Goldie, Bats for Lashes, amongst others. I think that's coming out next year. I think there's definite scope to do more. We'll just see what happens I guess. You discuss social issues like homelessness on Shedding Skin. Do you think the change of style in your music allowed you to change what you want to say in your lyrics? I have opinions, but I don't ever want to lead people down one particular path, and I didn't feel lyrically that I wanted to make a shift as well. I definitely wanted to make sure that it was very much about the everyday, be it in my life or others', and I think it's a continuation that I've developed as a songwriter. I want to keep developing and there's still room for improvement. With each album, it's clear you experiment and offer something different each time. Have you had thoughts of what sounds you want to explore for a next project? I want to continue down the guitar route, but I'm not sure what. I've been listening to lots of different things, and it's the double edged sword of liking to explore all different types of music. It's hard for me to pinpoint down one particular direction. There's four or five different directions I could go down, so it's working out what makes sense now, at the present, and then seeking out the right influences, and taking it further from there. Do you get annoyed that people try to pigeonhole your music into a genre you don't associate it with? Yeah, short and simple. I completely understand why. It's what our society is built on, the innocence of making it easier to understand. If you can package something, you can position it in particular spots of your shop and online. I think we're in a time now where genre is irrelevant and people listen to a myriad of sounds overall, and can appreciate and digest something that isn't down one particular straight genre path, so that's why I keep fighting against it. I'm not even fighting against it, I'm just doing what I want to and it will continue. In Tramlines, they've put me down as spoken word or something, which is annoying because it's not the case, but what can you do? All I can do is do what I want and leave it as that. I'm a recent graduate. You said going to university opened your eyes because you met different types of people and got on the road to making your own music. Any advice to budding musicians and graduates? It's just so important to do what you want, and don't think about the money and fame and where you want to be. It's very much the case of following a musical path that you enjoy and making music initially that always makes you happy, and I think when you do that it will come across as genuine. People want the truth. They want realness, and if you can provide that and put across your story regardless of what it is, if it's your story then people are interested in it. As a listener of music, as a fan of music, I want to hear about your story, not a recycled tale or recycled style. As we get older as a world, there's less and less scope to create new genres and everything is becoming strands and mashed into one. What is still unique to individuals is their truth, and I think that's important. )

redpajama_set_name: RedPajamaCommonCrawl


text:
RMU News
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Colonial Sports Network
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RMU Sentry Media
Sports Showcase
Israel: 'We just have to play a full 60 minutes'
Michael Sciulli and Luke Yost
Michael Sciulli, Sports Copy Editor
PITTSBURGH — Robert Morris University men's hockey team (8-13-1, 7-8-1 AHA) will look to snap their four game losing streak this weekend when they travel to Buffalo, New York to take on the Canisius Golden Griffins (8-11-2, 5-9-1 AHA) .
RMU is entering this two-game weekend series a week after being swept at home in a pair of games by the Bentley University Falcons (7-11-2, 6-7-1 AHA). In these two games, the Colonials were outscored by the Falcons 10-3.
After practice Wednesday morning, senior defenseman Eric Israel and assistant head coach Kody Van Rentergem were both locked in and focused on what needs to happen in order for Robert Morris to secure their first victory of the new calendar year.
In order to do this Israel said, "We just have to play a full 60 minutes." He continued to say, "We have spurts of dominance during those games, but then we lose focus." The team's leading scorer among defensemen went on to say that "playing together and being a single unit" in addition to playing a full 60 minutes will not just help the team grab their first win of 2019, but it will also give them a spark heading into the playoffs.
Van Rentergem then addressed the team's defensive issues over the course of the team's current losing streak. He said, "I think the first thing that we gotta take care of is compete level." Van Rentergem then stated "We just haven't competed enough, or hard enough I should say." He continued to mention that this is the first thing, because, "without that, you're not gonna have any success."
The assistant head coach then went on to his second point which addressed individual responsibility in the defensive zone. "It's details in our own end, and if each guy takes care of their own details, I think we should be successful," said Van Rentergem.
Israel also talked about winning individual battles on the defensive end. "It comes down to owning that that one on one battle it's your job to win that battle." He then went on to talk about how that they have to have trust in each other to do their job in the defensive end. Israel ended his statement with "Ultimately, we just have to bear down and do the little things right, get pucks out, get pucks deep at the two blue lines, and we haven't been doing that and that's really what's been costing us in the last couple of games there."
As for what Canisus brings to the table, Van Rentergem talked about the Golden Griffins speed. "I think they play with a lot of pace, which is difficult for any team to really deal with, when a team is coming at you full speed the whole game," said Van Rentergem. He continued to say that the Colonials will need to find way to slow down the Golden Griffins.
Men's hockey returns to the ice on Friday as they travel to Buffalo to take on the Canisius Golden Griffins in a two-game set.
Golden Griffins
Michael Sciulli, CSN Co-DCM
Michael Sciulli is a sophomore Sports Communications major with a minor in Sport Management. Sciuli has been writing and broadcasting since his freshman...
Luke Yost, Sports Multimedia Editor
Luke is a sophomore Sports Communications major. Luke is a sports writer for RMU Sentry Media. He is the assistant producer of Colonial Sports Center and...
Review: Cuphead (Nintendo Switch)
Scote's G.O.A.T.S. – Killer Bean Forever
Union Real Estate to turn former K-Mart into new shopping plaza
RMU changes start of semester to January 19, cancels 2021 Spring Break
Review: "Nectar" by Joji
Robert Morris University announces tentative plan for Spring 2021 semester
Review: "Animaniacs" (2020)
The importance of environmental conservation
Top 10 Electronic albums of the 2010s
The news site of Robert Morris University
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While the Eastern enlargement of the EU was met with favorable public attitudes in member states at the time, today, the potential membership of countries in the Western Balkans, and even more so Turkey, meets strong public opposition. The review of public attitudes provides inconclusive explanations for the shift to negative public opinion trends since 2004/2007, motivating us to seek understanding through a dis¬cursive approach studying citizens' views. This paper summarizes the results of six bottom-up, Q method discourse studies in Germany, the Netherlands, Poland, Bulgaria, Serbia, and Former Yugoslav Republic of Macedonia (FYROM). The comparison of 21 discourses from these six countries reveals the existence of groups of narratives that support enlargement, but also groups that oppose it. Analyzing the arguments within and across narratives, the paper outlines the limitations and opportunities for EU enlargement, stemming from the way European citizens/voters have perceived the process so far and how they envi¬sion it in the future. The identified discourses are more optimistic about future enlargements than mass surveys suggest. Nevertheless, the results clearly point to the lack of deliberation and communication on enlargement as a major problem of previous and current enlargement rounds. The real danger for future enlargement does not stem from negative opinions per se. Rather, enlargement process nowadays is at risk due to the absence of a bridging discourse that echoes across societies and elites and is rooted in common European values and ideals. The paper's policy recommendations emphasize that deliberation, consulta¬tion, and communication leading to a balanced public and political domestic debate are required at early stages of the process.


Locksmith Mission Hills is one of the few honest locksmiths around. Some other locksmiths will quote you a price then when the job is done come up with reasons to charge you more. We don't EVER allow our technicians to do this. We service everywhere in LA County and some of Ventura County as well. Locksmith Mission Hills makes sure that we are ready to handle any Locksmith emergency you may have. We are fully mobile and our professional technicians can provide service to your House, Apartment, Vehicle, or place of business we are there for you any day any time. We will respond to your location any where in the Los Angeles County, California, with every tool and part needed to perform the job with top quality and finish the job quickly.
Locked out In Mission Hills? Lost car keys in Mission Hills? Automotive Locksmith Mission Hills will safely pick the lock or make a new key. We can also make extra car keys for you so you have a spare in case it happens again.


The wordbankr package allows you to access data in the Wordbank database from R. This vignette shows some examples of how to use the data loading functions and what the resulting data look like.
There are three different data views that you can pull out of Wordbank: by-administration, by-item, and administration-by-item. Additionally, you can get metadata about the sources and instruments underlying the data. Advanced functionality let's you get estimates of words' age of acquistion and word mappings across languages.
The get_administration_data() function gives by-administration information, either for a specific language and/or form or for all instruments.
The get_item_data() function gives by-item information, either for a specific language and/or form or for all instruments.
If you are only looking at total vocabulary size, admins is all you need, since it has both productive and receptive vocabulary sizes calculated. If you are looking at specific items or subsets of items, you need to load instrument data, using the get_instrument_data() function. Pass it an instrument language and form, along with a list of items you want to extract (by item_id).
By default get_instrument_table() returns a data frame with columns of the administration's data_id, the item's num_item_id (numerical item_id), and the corresponding value. To include administration information, you can set the administrations argument to TRUE, or pass the result of get_administration_data() as administrations (that way you can prevent the administration data from being loaded multiple times). Similarly, you can set the iteminfo argument to TRUE, or pass it result of get_item_data().
Loading the data is fast if you need only a handful of items, but the time scales about linearly with the number of items, and can get quite slow if you need many or all of them. So, it's a good idea to filter down to only the items you need before calling get_instrument_data().
The get_instruments() function gives information on all the CDI instruments in Wordbank.
The get_sources() function gives information on all the data sources in Wordbank, either for a specific language and/or form or for all instruments. If the admin_data argument is set to TRUE, the results will also include the number of administrations in the database from that source and the minimum and maximum ages of those administrations.
The fit_aoa() function computes estimates of items' age of acquisition (AoA). It needs to be provided with a data frame returned by get_instrument_data() – one row per administration x item combination, and minimally the columns age and num_item_id. It returns a data frame with one row per item and an aoa column with the estimate, preserving and item-level columns in the input data. The AoA is estimated by computing the proportion of administrations for which the child understands/produces (measure) each word, smoothing the proportion using method, and taking the age at which the smoothed value is greater than proportion.
One of the item-level fields is uni_lemma ("universal lemma"), which is intended to be an approximate semantic mapping between words across the languages in Wordbank. The function get_crossling_items() simply gives all the available uni_lemma values.
The function get_crossling_data() takes a vector of uni_lemmas and returns a data frame of summary statistics for each item mapped to that uni_lemma in any language (on WG forms). Each row is combination of item and age, and the columns indicate the number of children (n_children), means (comprehension, production), standard deviations (comprehension_sd, production_sd), and item-level fields.


text:
Grayden is an unincorporated community in Fayette County, West Virginia, United States. It was also known as Free Union.

The community was named for the local Graydon family.

References

Unincorporated communities in West Virginia
Unincorporated communities in Fayette County, West Virginia

redpajama_set_name: RedPajamaWikipedia


FPGA engineers are engineers that are responsible for working with Field-programmable gate arrays � boards which can be initialised and programmed to do a range of different jobs, including managing the operation of heavy machines and more delicate electronics as well.... 23/08/2016�� Doing an FPGA is a nearly trivial task that many engineers can do without specialized knowledge or education. Doing a custom ASIC is a whole other proposition. I'd learn how to use and apply microcontrollers first.
FPGA engineers are engineers that are responsible for working with Field-programmable gate arrays � boards which can be initialised and programmed to do a range of different jobs, including managing the operation of heavy machines and more delicate electronics as well.
We are currently looking for a FPGA Engineer to join a Leading Global High Frequency Trading firm in Singapore. You will become a part of the technology team that designs, develops and optimizes FPGA solutions for automated trading systems.
The national average salary for a FPGA Engineer is $116,036 in United States. Filter by location to see FPGA Engineer salaries in your area. Salary estimates are based on 850 salaries submitted anonymously to Glassdoor by FPGA Engineer employees.


text:
Q: HTML markup in mail private void button1_Click(object sender, EventArgs e)
{
    if (check() == true)  // True: sends mail
    {
        try
        {
            // Mailmessage wordt gedeclareerd (hiermee kan je mails sturen)
            MailMessage mail = new MailMessage();
            // SMTP server van GMAIL wordt hier aangegeven
            SmtpClient smtpali = new SmtpClient("smtp.gmail.com");

            mail.From = new MailAddress("xxxxxx@gmail.com");
            mail.To.Add("xxxxxx@gmail.com");
            mail.Subject = "Test Mail";
            mail.Body = "Beste gebruiker";
            smtpali.Port = 587;
            smtpali.Credentials = new NetworkCredential("user", "xxxxxxx");
            smtpali.EnableSsl = true;
            smtpali.Send(mail);
            MessageBox.Show("Mail is verzonden!");
        }
        catch (Exception ex)
        {
            MessageBox.Show(ex.ToString());
        }
    }
    else
    {
        MessageBox.Show("Verkeerde combinatie!");
    }
}

Hello everyone. I've created a login system in C# and just finished the "resend password" form. This form sends a mail to the user with his password (plain and simple). I was wondering, what way can I use HTML markup in the body:
mail.Body = "content here"

I tried using:
mail.Body = "
content here
"

...et cetera but that is ofcourse plain text. Any suggestions for my case?

A: Set MailMessage.IsBodyHtml to true.
mail.IsBodyHtml = true;

A: You should set IsBodyHtml to true for this to work.

A: Try using mail.IsBodyHtml = true; in your code

redpajama_set_name: RedPajamaStackExchange


text:
Christian, William. "George Grant". The Canadian Encyclopedia, 16 December 2013, Historica Canada. https://www.thecanadianencyclopedia.ca/en/article/george-grant. Accessed 21 January 2020.
Christian, W., George Grant (2013). In The Canadian Encyclopedia. Retrieved from https://www.thecanadianencyclopedia.ca/en/article/george-grant
Christian, William, "George Grant". In The Canadian Encyclopedia. Historica Canada. Article published September 07, 2009; Last Edited December 16, 2013. https://www.thecanadianencyclopedia.ca/en/article/george-grant
Christian, William. The Canadian Encyclopedia, s.v. "George Grant", Last Edited December 16, 2013, https://www.thecanadianencyclopedia.ca/en/article/george-grant
Article by William Christian
Published Online September 7, 2009
Grant, George Parkin
George Parkin Grant, political and religious philosopher (b at Toronto 13 Nov 1918; d at Halifax 27 Sept 1988), son of William Lawson Grant, principal of Upper Canada College and grandson of George Monro GRANT, principal of Queen's University and Sir George PARKIN, founding secretary of the Rhodes scholarships. A public intellectual and one of the most influential Canadian thinkers of his age, Grant was a Christian and a Platonist who always thought of philosophy in terms of its Greek root words that mean "love of wisdom."
Educated in history at Queen's and theology at Oxford, Grant taught philosophy at Dalhousie from 1947 to 1960, then joined and almost immediately resigned from York University on a point of academic principle. He then joined the department of religion at McMaster. In 1980 he returned to Dalhousie as a professor of political science, classics and religion.
An extraordinary public communicator, his first book, Philosophy in the Mass Age (1959), began as a series of CBC lectures. In it he posed the question of how human beings could reconcile moral freedom with acceptance of the view that an order existed in the universe beyond space and time. In 1965, furious that the Liberal government had accepted nuclear weapons, he published LAMENT FOR A NATION. This short work created a sensation with its argument that Canada was destined to disappear into a universal and homogeneous state whose centre was the United States. Technology and Empire (1969), a collection of essays edited by poet and friend Dennis Lee, deepened his critique of technological modernity and Time as History, his 1969 Massey lectures, explained the worsening predicament of the West through an examination of the thought of Friedrich Nietzsche. Grant's works of the 1960s had a strong influence on the nationalist movement of the 1970s, though many of the New Left were uncomfortable with Grant's deep though unconventional religious thought.
In the 1970s Grant's writings began to change. Previously he had been concerned with how to communicate his thought to a wide audience, as his radio broadcasts indicate. Now, although he never wrote in jargon or for a professional audience, his writings became more complex and placed greater demands upon the reader. English-Speaking Justice (1974) asked the Platonic question of how we could know that we had a duty to treat other human beings justly, especially after the American Supreme Court had declared that a fetus was not a person. Grant was beginning to come to the conclusion that the science of human and non-human nature, which had begun 400 years earlier with Francis Bacon, had led to a society in which human beings were not fitted to live.
His last collection of essays was Technology and Justice (1986), which he prepared together with his wife Sheila Grant. Drawing on his 30-year meditation on the French philosopher Simone Weil, he came to the conclusion that western civilization was fundamentally flawed, both morally and spiritually. It was fated to disappear and was collapsing from within. As a Christian, however, Grant expressed faith that something nobler would replace it. During his lifetime Grant's reputation was primarily as a political thinker. Since his death, attention has increasingly focussed on the religious dimension of his thought, and many scholars consider him one of the most original Canadian theologians of the second half of the twentieth century.
In spite of these views, Grant received many honorary degrees, as well as The Order of Canada and many other honours.
Charles Taylor, Radical Tories: The Conservative Tradition in Canada (1982); William Christian, George Grant: A Biography (1993); William Christian and Sheila Grant, The George Grant Reader (1997).
Wilfred Pelletier
Bernard Joseph Francis Lonergan