Companies should develop plans to ensure both tax and financial reporting compliance.
The IRS determined a taxpayer’s substantial renovation, construction, and erection of certain property qualified as the construction of real property under Sec. 199.
The IRS issued final regulations clarifying the definition of real property for purposes of the REIT provisions.
Ascertaining the Tax Impact on the Shareholder of a Corporate Assumption of Liabilities in a Sec. 351 Transfer
The transfer of debt to a corporation will create a taxable event in some situations.
A taxpayer that treats a split-off transaction as a tax-free D reorganization must be able to prove to the IRS that the transaction meets all requirements.
The application of the business purpose and device rules often involves both legal and factual questions.
Final regulations expand on and modify the proposed rules that curb the practice of “earnings stripping."
The expiring provisions include tax incentives for individuals and businesses, as well as several energy provisions.
Taxpayers that develop software for their own internal use will be able to claim a credit for research and development expenditures in some cases.
Personal service corporations risk having compensation reclassified as dividends, which are subject to double taxation.
IC-DISC provides a permanent tax benefit to entities that export products that are manufactured, grown, or extracted in the United States.
Real property developed and held by a taxpayer for lease in its leasing business is “real property used in a trade or business.”
Recently issued advice clarifies some of the rules regarding the limitations on the amount of the exclusion.
These transfers are considered a nontaxable contribution of capital by a nonshareholder to the utility.
In this case, compensation paid by a closely held corporation was reasonable and therefore deductible.
A Sec. 338 election can provide benefits to buyer and seller, but the transaction must be structured so that it satisfies the conditions to be a qualified stock purchase.
An S corporation was not eligible to elect the safe harbor since it was the target of the acquisition, and it must capitalize the success-based fees that it claimed as an expense.
The fees were unnecessary because the taxpayer did not provide proof to show that any services were actually performed in exchange for the fees.
Many countries have implemented preferential tax systems to bolster incentives to keep research and innovation activities onshore.
The new rules are part of the Treasury Department’s larger effort to curb corporate inversions.