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Articles by Christopher Hesse
The maze of real estate rentals
EXECUTIVE SUMMARY Rental real estate activities are per se passive but in certain circumstances are subject to recharacterization. If the taxpayer meets the requirements to be a rental real estate professional, a rental real estate activity will be nonpassive if the taxpayer materially participates in the activity. Rental income will not be subject to the net investment income tax if it is derived from a trade or business that is not a passive activity.
Procgen Benchmark
We’re releasing Procgen Benchmark, 16 simple-to-use procedurally-generated environments which provide a direct measure of how quickly a reinforcement learning agent learns generalizable skills.
Idaho Society of Certified Public Accountants (ISCPA)
December 2, 2019 By Christopher W. Hesse, CPA December 1, 2019 Some small businesses that otherwise qualify might not be permitted to use the cash method of accounting or certain provisions that simplify record keeping because of a quirk introduced by the Tax Cuts and Jobs Act. Find out which businesses might not qualify. EXECUTIVE SUMMARY The law known as the Tax Cuts and Jobs Act, P.L. 115-97, contains certain provisions that simplify recordkeeping for small businesses.
A quirk in the TCJA’s small business exceptions
EXECUTIVE SUMMARY The law known as the Tax Cuts and Jobs Act, P.L. 115-97, contains certain provisions that simplify recordkeeping for small businesses. If a business has average annual gross receipts of $25 million or less, it is permitted to use the cash method of accounting and is spared from having to comply with a variety of burdensome requirements.
Simplifying the Rube Goldberg tax code
“Life is really simple, but we insist on making it complicated.” — attributed to Confucius The income tax system is a montage of provisions piling upon provisions. Changes are made to fix the unintended consequences of earlier changes. Resourceful taxpayers and their advisers discover means (some valid, some not so valid) to avoid (if not evade) income taxes otherwise due.
Traps for the unwary: Tax Cuts and Jobs Act changes
By now many of us are familiar with the various provisions of the law known as the Tax Cuts and Jobs Act (TCJA), P.L. 115-97. We have attended or taught continuing professional education on the changes, but we might not be aware of the full import of the changes. Here is a list of changes together with (perhaps) unexpected nuances.
Questions remain about the excess business loss rule
P.L. 115-97, informally known as the Tax Cuts and Jobs Act (TCJA), added Sec. 461(l) and the phrase "excess business losses" to the Code. Little has been written about the excess business loss rule. Perhaps people believe it to be straightforward and not worthy of comment. However, IRS guidance is needed to determine items of business income, gains, losses, and deductions to arrive at the amount of excess business losses.
Retro Contest: Results
The first run of our Retro Contest—exploring the development of algorithms that can generalize from previous experience—is now complete. Though many approaches were tried, top results all came from tuning or extending existing algorithms such as PPO and Rainbow. There's a long way to go: top performance was 4,692 after training while the theoretical max is 10,000.
Gym Retro
We're releasing the full version of Gym Retro, a platform for reinforcement learning research on games. This brings our publicly-released game count from around 70 Atari games and 30 Sega games to over 1,000 games across a variety of backing emulators. We're also releasing the tool we use to add new games to the platform. We use Gym Retro to conduct research on RL algorithms and study generalization. Prior research in RL has mostly focused on optimizing agents to solve single tasks.
Retro Contest
We're launching a transfer learning contest that measures a reinforcement learning algorithm's ability to generalize from previous experience. In typical RL research, algorithms are tested in the same environment where they were trained, which favors algorithms which are good at memorization and have many hyperparameters. Instead, our contest tests an algorithm on previously unseen video game levels.
A 2017 federal tax deduction for prepaying anticipated 2018 state income taxes? Not likely!
In anticipation of enactment of the House and Senate proposed federal tax legislation, some commentators and tax practitioners are suggesting that — in view of the likely elimination of the state income tax deduction for 2018 and subsequent years — individual taxpayers prepay their 2018 state income tax liability and claim the deduction on their 2017 federal income tax returns.
Passive activity credits and recharacterized income
The Internal Revenue Code includes various tax incentives to encourage certain economic and social behavior. Depending on the investor's participation level, however, the promised tax benefits might not arise. Passthrough owners that do not materially participate in a trade or business may find their tax credits suspended under the passive activity rules.
There is no 'small partnership' exception for taxes
Neil Harl is entitled to his own opinion but not his own facts [Congress’ secret tax threat to farmers, small businesses, March 29]. There are many, many tax attorneys and CPAs that specialize in partnership taxation. To my knowledge, these other tax attorneys and CPAs, to a person, disagree with Harl’s interpretation of the Internal Revenue Code prior to the change in late 2015. There is no small partnership exception to filing a partnership tax return.
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