Architecture and engineering firms often face challenges when seeking to claim the Sec. 41 research-and-development tax credit for their work on building and construction projects, as two recent court cases illustrate. However, by understanding the requirements to claim the credit and carefully planning, executing, and substantiating a project, they may be able to qualify for it.
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C Corporation Income Taxation
Company’s $1.6 billion ‘break fee’ payment treated as ordinary deduction
A proposed merger agreement’s rights and obligations were in the nature of services, so a fee paid to terminate was not treated as a capital loss, the Tax Court held.
IRS ruling clarifies treatment of R&D when computing the FDII deduction
IRS rules research and development services U.S. entities provide to their foreign parent principal company may be characterized entirely as foreign-derived deduction eligible income purposes.
IRS withdraws prop. regs. affecting corporate spinoff transactions
The proposed regulations were withdrawn in response to comments that criticized the proposed guidance, according to the IRS.
AI is transforming transfer pricing
Mimi Song, COO, Exactera, discusses how AI can improve transfer pricing compliance.
Guidance on research or experimental expenditures under H.R. 1 issued
The revenue procedure advises taxpayers how to make various elections, file amended returns, and change accounting methods as provided under Section 70302 of the new law.
AICPA presses IRS for guidance on domestic research costs in OBBBA
In its letter, the AICPA said small businesses that have not filed returns for the 2024 filing period face uncertainty about how to treat domestic research and experimental expenditures.
IRS includes several AICPA recommendations in corporate AMT interim guidance
In a notice issued Tuesday, the IRS said it intends to partially withdraw proposed regulations and issue revised proposed regulations.
Impact of ‘beginning of construction’ on Inflation Reduction Act credits
Taxpayers may be able to claim the PWA multiplier for certain credits if a project’s “beginning of construction date” is before Jan. 30, 2023.
A transfer pricing paradox: High-risk transactions remain underrepresented in APAs
Intangible property transactions are a minority of those covered by advance pricing agreements, despite their generally high risk for taxpayers.
Sec. 181: Will 2025 be the series finale?
Sec. 181 expensing of costs of qualified film, television, and theatrical productions gives producers cause to cheer, but the curtain may be falling on this temporary provision.
Clean fuel production credit: Regulatory roadblocks ahead
Early guidance for the new Sec. 45Z clean fuel production credit raises concerns regarding the eligibility of fuel sales to wholesalers.
Federal excise tax traps for the unwary
Editor: Mary Van Leuven, J.D., LL.M. The U.S. government imposes federal excise taxes that can affect a surprising variety of companies. These taxes include the foreign insurance excise tax, the Patient–Centered Outcomes Research Institute (PCORI) fee, and the relatively new stock repurchase excise tax. Compliance with these taxes can be
Global expansion of e-invoicing and digital reporting obligations for nonresidents
Countries are expanding e-invoicing and digital reporting obligations to nonresidents to increase value-added-tax compliance.
Strategic trade management in 2025: Navigating and mitigating tariffs
As tariffs continue to affect costs, U.S. importers can employ these strategies to minimize their duty exposure.
CHIPS Act final regs. offer many taxpayer-friendly provisions
Congress incentivized domestic manufacturing of semiconductors and semiconductor manufacturing equipment as part of the Creating Helpful Incentives to Produce Semiconductors (CHIPS) Act of 2022.
AICPA makes Priority Guidance Plan recommendations to IRS
In addition to its 183 recommendations for the IRS plan, the AICPA encouraged the agency to continue to pursue tax simplification.
Appeals court leaves tariffs in place, seeks expedited argument schedule
A federal appeals court extended its stay of a nationwide injunction on tariffs imposed by a trade court and proposed a schedule that would include oral arguments on July 31 in the challenge to the president’s authority.
The proposed PTEP rules: Tax basis considerations under Sec. 961
Proposed regulations for previously taxed earning and profits of foreign corporations address a range of considerations for shareholder basis adjustments.
Using transfer pricing to blunt the effects of tariffs
Understanding the interrelationship of transfer pricing and tariffs is key to mitigating the effect of those levies on earnings.
TAX PRACTICE MANAGEMENT
2025 tax software survey
AICPA members in tax practice assess how their return preparation software performed during tax season and offer insights into their procedures.
