IRS issues first guidance on new business interest limitation
The IRS issues guidance on business interest limitation under the new tax act.
Corporations
Code’s plain language prevails, despite anomalies
The owner of a hotel and restaurant complex was not entitled to capital gains treatment under Sec. 1234A for a deposit it retained after a would-be buyer terminated a contract to purchase the complex.
Application of Sec. 199A deduction to health care
While businesses involving the performance of services in the health care field were generally understood as not qualifying for the Sec. 199A deduction, further analysis could provide a favorable result.
Deducting deferred bonuses
Numerous rules and restrictions govern the timing of deductibility of bonuses accrued in one year and paid in another.
Casualty losses and expenditures under Sec. 162 or 165
Two Code provisions, Sec. 162 and Sec. 165, offer a potential deduction for a taxpayer who has property that has been damaged by a casualty.
Congress extends expired provisions
The Bipartisan Budget Act of 2018 has many tax provisions, including retroactive extensions of a number of tax credits.
Upstream, downstream: Upstream C reorganizations with a drop
The transaction accomplishes a distribution of assets to the parent, which may be effected in a tax-free manner only in limited circumstances.
Sec. 199 deduction for qualified film and the IRS compliance campaign approach
The IRS has created an LB&I compliance campaign that affects multichannel video programming distributors and television broadcasters.
Converting from S corp. to C corp.: Select issues for consideration
As a result of tax reform, which provides for a significant decrease in the corporate tax rate and a more modest decrease in passthrough tax rates, business owners may consider revoking S corporation elections.
Businesses affected by winter storms get extra time to file for extensions
The extension to March 20 applies to business taxpayers affected by the two recent winter storms, Quinn and Skylar, that primarily hit the Northeast and Mid-Atlantic United States.
IRS revisits General Utilities repeal
Provisions relating to the repeal of the General Utilities doctrine may again face scrutiny.
SEC permits reasonable estimates of tax liability to ease effect of new tax law
SEC allows companies to use reasonable estimates of their tax liability post-tax reform.
Bipartisan Budget Act contains several tax provisions
The Bipartisan Budget Act of 2018 has many tax provisions, including retroactive extensions of a number of tax credits.
Statistical sampling makes it easier to claim a research tax credit than ever before
Not just large but also medium-size and even smaller companies can more easily take a RTC now that the IRS allows multiple tax years under one statistical sample study.
A new safe harbor for LB&I taxpayer R&D credits
A new directive allows taxpayers to use R&D costs reported on FASB ASC financial statements as the starting point for computing QREs.
IRS memorandum provides clarity on treatment of debt-issuance costs
The IRS concluded that a taxpayer could deduct the unamortized debt-issuance costs related to its existing debt upon its exchange for new debt.
Congress enacts tax reform
This column summarizes the federal tax law changes under reform enacted in December.
SEC permits reasonable estimates in corporate tax reporting
Companies may initially have difficulty determining the effects of the new federal tax law on their income tax reporting.
Safe harbor eliminates need for private letter ruling for some REIT and RIC distributions of stock and cash
The IRS established a safe harbor allowing distributions of stock to be treated as a distribution of property under Secs. 301 and 305(b) for publicly offered REITs or publicly owned RICs, as long as certain conditions are met.
Income from receipt of carbon sequestration credits relating to timberlands is qualifying REIT income
The IRS ruled it would consider income recognized by a REIT in connection with the receipt of carbon sequestration credits to be income qualifying the taxpayer to be a REIT.
