C Corporation Income Taxation

GILTI rules address income subject to high foreign tax rate

The IRS issued final regulations under the global intangible low-taxed income (GILTI) rules on the treatment of income subject to a high rate of foreign tax. At the same time, the IRS issued proposed rules conforming the GILTI high-tax exception rules with the Subpart F high-tax exception.

Consolidated groups get NOL guidance

The IRS issued proposed and temporary regulations explaining how consolidated groups should apply the changes to the net operating loss rules enacted by the CARES Act.

IRS says PPP expenses nondeductible, but AICPA disagrees

The IRS issued guidance clarifying that a deduction is disallowed for expenses for payroll costs, mortgage interest, rent, utilities, and other interest on debt obligations to the extent they are being reimbursed by loans forgiven under the Paycheck Protection Program.

Tax savings opportunities from the CARES Act

This article summarizes business and individual tax provisions of the CARES Act, emergency legislation designed to speed relief to employers and individuals who are struggling due to the COVID- 19 pandemic.

Elective capitalization as a TCJA planning tool

Taxpayers whose overall tax position in a given year would benefit from accelerating gross income or from converting current deductions into capital expenditures should consider the elective capitalization provisions of Sec. 266.

Hedging transactions: Timing of gain or loss

While the U.S. federal income tax rules generally provide comprehensive instruction on tax hedging transactions, ambiguity remains regarding the timing for transactions intended to hedge anticipated, but unfulfilled, transactions.

AICPA challenging nondeductibility of PPP-related expenses

The IRS issued guidance clarifying that a deduction is disallowed for expenses for payroll costs, mortgage interest, rent, utilities, and other interest on debt obligations to the extent they are being reimbursed by loans forgiven under the Paycheck Protection Program.

Newsletter Articles

50th ANNIVERSARY

50 years of The Tax Adviser

The January 2020 issue marks the 50th anniversary of The Tax Adviser, which was first published in January 1970. Over the coming year, we will be looking back at early issues of the magazine, highlighting interesting tidbits.

TAX RELIEF

Quirks spurred by COVID-19 tax relief

This article discusses some procedural and administrative quirks that have emerged with the new tax legislative, regulatory, and procedural guidance related to COVID-19.