Export tax incentives after the Tax Cuts and Jobs Act
The TCJA introduced a new export tax incentive — the Sec. 250 deduction for foreign-derived intangible income — that is available only to domestic C corporations.
C Corporation Income Taxation
How to determine whether interest in corporation is stock or debt
The IRS has issued final regulations addressing when certain related-party interests in corporations should be treated as stock vs. debt.
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.
Liquidity and cash management strategies during a pandemic
The CARES Act creates several opportunities for businesses to shore up cash flow.
Characterizing multistep transactions: Form can make the difference
This discussion explores the step transaction doctrine and the facts, analysis, and rulings of Rev. Ruls. 2001-46 and 2008-25, then analyzes the rulings to illustrate how form can make a difference in multistep transactions.
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.
Beware the personal holding company tax
Closely held corporations must test whether the personal holding company tax applies and what measures to take to avoid it.
Top 10 business income tax planning ideas for the pandemic
Right now, some basic tax planning ideas can make a significant difference in reducing income tax, thereby increasing cash flow and even creating tax refund opportunities.
Proposed regs. explain disallowed transportation fringe benefits
The IRS issued proposed regulations implementing changes to Sec. 274 that disallow a deduction for the expense of any Sec. 132(f) qualified transportation fringe provided to an employee, effective for amounts paid or incurred after Dec. 31, 2017.
Leave-based donation program available during pandemic
The IRS announced that employers may make donations this year to charitable organizations that provide relief to COVID-19 pandemic victims in exchange for personal leave that their employees forgo.
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.
IRS issues Form 7200 for advance payment of employer tax credits, explains employee retention credit
The IRS issued a new form and instructions for employers to use to obtain advance payments of three tax credits that were created to help businesses cope with the coronavirus pandemic.
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.
Disallowance of deduction for FDIC premiums under Sec. 162(r)
No deduction may be claimed for FDIC premiums paid or accrued by taxpayers with total consolidated assets of $50 billion or greater.
Deduction limitations of Sec. 162(m) to compensation paid by partnerships in Up-C and UPREIT structures
Proposed regulations change the paradigm for the tax treatment of compensation paid by a partnership situated below a publicly held corporation in an Up-C or UPREIT structure.
Final regs. clarify when interest in corporation is stock vs. debt
The IRS has issued final regulations addressing when certain related-party interests in corporations should be treated as stock vs. debt.
Proposed rules govern deductions and reporting for restitution
The IRS issued regulations explaining the allowance of deductions for certain fines and penalties under Sec. 162(f) as amended by the law known as the Tax Cuts and Jobs Act.
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.
