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ACC307 Federal Taxation "Temporary Regulations" Please respond to the following (One Paragraph): You have been assigned a research project for a new client on the issue of tax compliance. The research...

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ACC307 Federal Taxation

"Temporary Regulations" Please respond to the following (One Paragraph):

You have been assigned a research project for a new client on the issue of tax compliance. The research results for the client fall under a temporary regulation. Evaluate and describe two (2) types of temporary regulations and explore the effects on the taxpayer. Discuss the weight of the temporary regulation and what issues may strengthen or weaken the temporary regulation.

Answered Same Day Dec 26, 2021

Solution

Robert answered on Dec 26 2021
127 Votes
Two activities that affect the new client who is looking to invest in US:
1) Commercial activities (temporary regulations)-
This regulation states that any activity (whether within or outside the United States)
which is conducted by the taxpayer or by any other person with a view
towards generation of income are commercial activities. An activity may be considered
a commercial activity even if such activity does not constitute the conduct of a trade or
usiness in the United States under section 864(b).
2) Foreign cu
ency guidance under section 987 (temporary regulations)-
As per this notice, taxpayers will not be able to recognize section 987 losses as a result
of filing retroactive check the box elections.
Temporary regulations have the same authority as final regulations, but they must
expire within three years But a temporary regulation will never become a final
egulation, but will simply expire, whereas a similar or identical version of the temporary
egulation that begins as a proposed regulation may eventually become a final...
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