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.
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 PATH Act of 2015 included important changes to the R&D credit.
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.
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.
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.
Tax problems and administrative difficulties can arise if a corporation is classified as a personal holding company.
Proper planning needs to take place to avoid the potential negative tax consequences and complexities of a taxable stock purchase.
Temporary and proposed regulations implement the amendments to the real estate investment trust spinoff rules.