The IRS withdrew rules it proposed in 2005 that would have required certain corporate formations and reorganizations to meet net value requirements before they would qualify for nonrecognition treatment.
When group policies are purchased from foreign insurance companies, there may be federal insurance excise tax issues.
The House Blueprint, if enacted, may provide incentives for certain taxpayers to merge in the future.
This column examines the meaning of the standard and discusses whether the economic substance doctrine still should be applied to a transaction that does not run afoul of the “with a view” standard.
This item discusses a methodology to sample expenditures by reviewing amounts capitalized for book purposes and to determine the extent to which they should be classified as tangible personal property or expensed for tax purposes.
This article examines the PATH act provisions and other developments favorable for taxpayers.
The Tax Court held that the owners of the Boston Bruins could deduct the full cost of their team’s pregame meals for away games as a de minimis fringe benefit.
Interim guidance on small business research tax credit allows amended returns to claim credit for 2016
Eligible small businesses can apply a portion of their R&D credit against their payroll tax liability under a new provision enacted in 2015.
Among the first wave of examination “campaigns” announced by the IRS’s LB&I is the application of the Sec. 199 domestic production activities deduction to “multi-channel video programming distributors.”
The IRS says it will again issue rulings on corporate leveraged spinoff transactions.
This item offers an overview of certain provisions in the regulations that could have state corporate income tax consequences.
The IRS could not recharacterize, under the substance-over-form doctrine, commissions paid by a DISC to two Roth IRAs as dividends..
This item presents an opportunity to minimize the tax impact of a distribution by a closely held corporation that is not made out of the corporation’s E&P.
This item focuses on stock redemptions, or transactions having the effect of a redemption, causing an ownership change.
The IRS is allowing calendar-year C corporations a six-month filing extension, instead of the five-month extension specified in the Code.
This column discusses examples of potential constructive dividends.
Taxpayers who have engaged in “micro-captive transactions,” which the Internal Revenue Service has designated as transactions of interest, have until May 1 to file the required disclosure statement.
The final regulations could provide opportunities for companies and industries that previously did not include expenditures for software developed primarily for their own internal use.
The proposed regulations are intended to further limit a corporation’s ability to separate business assets from nonbusiness assets in a tax-free manner.
Eligible small businesses can apply a portion of their research and development credit against their payroll tax liability, starting with 2016 tax years, under a new provision enacted in 2015.