The new rules are part of the Treasury Department’s larger effort to curb corporate inversions.
Software a taxpayer develops for its own general and administrative internal use can qualify for the research and development credit under regulations finalized by the IRS.
The proposed regulations target three types of transactions formerly considered well-established and routine mechanisms for creating internal leverage within a controlled group’s entity structure.
The PATH Act of 2015 included important changes to the R&D credit.
This item discusses the ability of a target in a Sec. 338(h)(10) transaction to use the safe-harbor election provided by Rev. Proc. 2011-29.
Tax problems and administrative difficulties can arise if a corporation is classified as a personal holding company.
This item addresses the tax consequences when a nonpublic, financially healthy company renegotiates a debt that was incurred to purchase the company’s assets, and the resulting new debt is contingent on the occurrence of future events.
Temporary and proposed regulations implement the amendments to the real estate investment trust spinoff rules.
Proper planning needs to take place to avoid the potential negative tax consequences and complexities of a taxable stock purchase.
A recent change in the law makes it easier for taxpayers to claim charitable deductions for food products donated to charity.
The IRS issued guidance that provides safe harbors for corporations, under which the IRS will not assert that a distributing corporation lacks control of another corporation within the meaning of Sec. 355(a)(1)(A).
There have been recent changes to the eligibility requirements for certain small captives to elect to be taxed only on their investment income.
The PATH Act of 2015 made several amendments to the prohibited transaction safe-harbor test that will apply for sales of property in 2016 and later tax years.
This item discusses these rulings along with the technical aspects surrounding their issuance and addresses whether the IRS reached the right results.
The regulations under Sec. 108(i) provide special rules for consolidated groups.
In the absence of records specifically created to document the research tax credit, taxpayers often have to rely on estimates and an assortment of documents, interviews, and other evidence to substantiate expenditures that qualify for the research tax credits.
The IRS issued regulations restricting the ability of C corporations to use this method.
A package of proposed and temporary regulations are designed to reduce the tax benefits and incentives for corporate inversions.
This item examines the potential application of Sec. 304 to transfers of interests in a partnership that owns corporate stock.
Foreign currency straddles may be used to manage foreign currency exposure, but they may carry hidden tax issues.