This item provides a brief history of existing tax law in this area and IRS guidance and a summary of the recent developments.
A taxpayer was not entitled to defer gain on a disposition of property to a related party that met the Sec. 1031(a) requirements for a like-kind exchange.
Carrying over E&P from one entity to another and administrative burdens can lead to headaches down the road.
The tension between the two principles of the new regulations can cause taxpayers uncertainty.
Taxpayers should expect to see continued controversy regarding when a liability is fixed for customer discounts.
This item outlines some of the more common themes that came out of the final and temporary regulations.
The final and temporary regulations substantially revised the proposed regulations, reducing their scope.
Companies should develop plans to ensure both tax and financial reporting compliance.
The IRS determined a taxpayer’s substantial renovation, construction, and erection of certain property qualified as the construction of real property under Sec. 199.
The IRS issued final regulations clarifying the definition of real property for purposes of the REIT provisions.
Ascertaining the Tax Impact on the Shareholder of a Corporate Assumption of Liabilities in a Sec. 351 Transfer
The transfer of debt to a corporation will create a taxable event in some situations.
A taxpayer that treats a split-off transaction as a tax-free D reorganization must be able to prove to the IRS that the transaction meets all requirements.
The application of the business purpose and device rules often involves both legal and factual questions.
Final regulations expand on and modify the proposed rules that curb the practice of “earnings stripping."
The expiring provisions include tax incentives for individuals and businesses, as well as several energy provisions.
Taxpayers that develop software for their own internal use will be able to claim a credit for research and development expenditures in some cases.
Personal service corporations risk having compensation reclassified as dividends, which are subject to double taxation.
IC-DISC provides a permanent tax benefit to entities that export products that are manufactured, grown, or extracted in the United States.
Real property developed and held by a taxpayer for lease in its leasing business is “real property used in a trade or business.”
Recently issued advice clarifies some of the rules regarding the limitations on the amount of the exclusion.