Determining whether an ownership change under Sec. 382 has occurred can hinge on understanding the shareholder aggregation and segregation rules.
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TOPICS
C Corporation Income Taxation
R&D tax credits: A new era of disclosure and documentation
The IRS’s increased documentation requirements for Sec. 41 claims require taxpayers to specifically identify applicable business components and their costs and why their development is qualified research.
Comparing and contrasting business tax strategies
Using the correct expensing strategy for items of real and personal property enables taxpayers to obtain the maximum tax benefits.
IRS renews corporate tax opportunities with letter rulings
After decades of limiting private letter ruling issues, the IRS has steadily widened its program, providing taxpayers greater certainty.
Commonly overlooked business property tax compliance and valuation issues
Updating their fixed-asset records and exploring state exemptions can create often-missed tax savings for businesses.
Income tax purchase accounting considerations for a stock acquisition
Business advisers can help guide clients through the tax and accounting considerations of a corporate sale or purchase.
The R&D tax credit for architects and engineers
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.
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The proposed regulations were withdrawn in response to comments that criticized the proposed guidance, according to the IRS.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.
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.
