C Corporation Income Taxation

PFIC considerations for non-US SPACs

As SPAC activity has increased, non-U.S.-domiciled SPACs have become more prevalent and carry major U.S. tax-compliance ramifications due to their potential treatment as a PFIC for U.S. investors.

Sec. 199A and Subchapter M: RICs vs. REITs

Sec. 199A, may create a potential difference in how the same type of income is taxed to shareholders of RICs and REITs and therefore offers an opportunity for fund managers.

Safe harbor allows 2020 PPP expenses to be deducted in 2021

The IRS issued guidance on a safe harbor permitting qualifying taxpayers who have PPP loans, who did not deduct expenses related to those loans paid or incurred in 2020 on their 2020 returns, to deduct the expenses on their returns for 2021.

Generic drug manufacturer can deduct patent infringement suit expenses

Legal expenses for notice letters required as part of an application to the FDA for permission to produce and market generic drugs are capitalizable, but legal expenses for patent litigation as a result of certain certifications made during the approval process are deductible.

IRS posts ARPA credit FAQs

The IRS has posted two sets of FAQs that explain changes to the child and dependent care credit and to the sick and family leave credits made by the American Rescue Plan Act.

President’s budget contains many tax proposals

The proposed $6 trillion fiscal year 2022 budget unveiled by the Biden Administration includes a host of tax items, including proposals to raise the corporate tax rate, raise the top tax rate for high-income individuals, limit like-kind exchanges, and make permanent recent temporary changes to various tax credits.

Tax Insider Articles

DEDUCTIONS

Business meal deductions after the TCJA

This article discusses the history of the deduction of business meal expenses and the new rules under the TCJA and the regulations and provides a framework for documenting and substantiating the deduction.

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.