Although the IRS has provided guidance on success-based fees, determining which parties are the acquirer and target can be difficult when multiple entities are involved in an M&A.
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TOPICS
C Corporation Income Taxation
IRS issues guidance on treaty application to reverse foreign hybrids
The IRS provides guidance on whether these entities qualify under a U.S. federal income tax treaty for relief from the branch profits tax.
Practical tax issues related to qualified reopenings
Treating multiple debt instruments as a single issuance under Sec. 1275 and its regulations can have tax advantages but is often overlooked.
Partner redemptions from ‘dry’ partnerships
A partnership whose sole asset is all the stock of a corporation offers opportunities but with potential pitfalls.
Navigating safe-harbor rules for solar and wind Sec. 48E facilities
Early termination of the clean energy investment credits for solar and wind under the law known as the One Big Beautiful Bill Act means projects must start construction by July 4, 2026.
Businesses urge Treasury to destroy BOI data and finalize exemption
Just over 100 business associations asked Treasury Secretary Scott Bessent to purge previously submitted beneficial ownership information records and quickly finalize a rule exempting U.S. companies from BOI reporting.
IRS generally eliminates 5% safe harbor for determining beginning of construction for wind and solar projects
A notice limits methods of meeting a key deadline for project eligibility for two clean energy credits, which recent legislation terminated after 2027.
Deducting corporate charitable contributions
Some key limitations and
requirements differ from those
with respect to individuals.
SECURE 2.0 amendment deadline extended for IRAs, other retirement plans
The IRS extended the deadline for SECURE 2.0 related amendments to IRAs, SEPs, and SIMPLE IRAs to Dec. 31, 2027, saying that additional time is needed to complete model language.
Revisiting Sec. 1202: Strategic planning after the 2025 OBBBA expansion
This powerful vehicle for excluding gain on qualified small business stock gains even more traction under new legislation.
Practical tax advice for businesses as a result of the OBBBA
H.R. 1, P.L. 119-21, the law commonly known as the One Big Beautiful Bill Act (OBBBA), contains provisions of special interest to business taxpayers. This article summarizes some of them and offers tax planning tips.
IRS updates FAQs on business interest limitation, premium tax credit
The updates reflect changes made in H.R. 1, P.L. 119–21, commonly known as the One Big Beautiful Bill Act.
Notice 2025-27 provides interim guidance on corporate AMT
The notice provides an optional interim simplified method of determining whether a corporation is an applicable corporation for purposes of the corporate AMT and relief from the Sec. 6655 penalty for underpayment of estimated tax with respect to a corporation’s corporate AMT liability.
Two Tax Court rulings expose overvalued conservation easements
In the cases, the Tax Court determined the value of a conservation easement donated to charity using the comparable sales method instead of the discounted-cash-flow method.
Late election relief in recent IRS letter rulings
The IRS may grant a reasonable extension if the taxpayer provides satisfactory evidence of acting reasonably and in good faith and the relief will not prejudice the government’s interests.
Sec. 382 and exceptions to the segregation rules
Determining whether an ownership change under Sec. 382 has occurred can hinge on understanding the shareholder aggregation and segregation rules.
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.
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.
