Before adopting the newly reinstated expensing of research and experimental expenditures, taxpayers should first consider the strategy’s broader tax effects.
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TOPICS
C Corporation Income Taxation
Sec. 163(j) after OBBBA: Leveraging cost-recovery accounting methods
A variety of capitalization strategies can increase deductible interest expense now that depreciation, amortization, and depletion are again added back to adjusted taxable income in calculating the Sec. 163(j) interest limitation.
Startups and the OBBBA: Rethinking C corporation vs. passthrough
With enhanced Sec. 1202 gain exclusion, permanency of Sec. 199A, and other provisions, the calculus for entity choice has shifted.
Practical considerations for NUBIL positions under Sec. 382
Proactive management of net unrealized built-in losses in ownership changes is increasingly important in today’s volatile markets.
New IRS rules for digital content and cloud transactions
Businesses that offer software, software as a service, or other digital content to customers should carefully assess the implications of recent final digital content and cloud transaction regulations and proposed cloud transaction sourcing regulations.
Using a GRAT or GRUT to shift appreciation and maintain control of the corporation
Use of a grantor retained annuity trust or grantor retained unitrust can mitigate the gift tax consequences of a gratuitous transfer of stock.
Calculating and presenting state income tax effects under ASC Topic 740
Help accounting students understand how public business entities incorporate state income taxes into the income tax provision with a detailed example.
Sec. 280E bars claim for refundable portion of ERC
The employee retention credit is among those prohibited under the section for taxpayers trafficking in federally controlled substances, the Tax Court held, finding against a marijuana dispensary business.
Final regs. modify reporting obligations for Form 8308, Part IV
The final regulations published Tuesday by the IRS stick with the proposed regulations that modify information-reporting obligations for Part IV of Form 8308, Report of a Sale or Exchange of Certain Partnership Interests.
AICPA submits nearly 200 recommendations for IRS guidance plan
The organization highlighted top technical issues across 10 areas and urged the IRS to prioritize tax simplification.
Identifying the final C corporation and initial S corporation tax years
Rules determine allowable tax years after a C corporation elects S status.
Access to energy: A ‘new’ intangible asset?
Some leases and other contracts for priority access to electricity needed for new technologies may require 15-year amortization under Sec. 197.
Demystifying reattribution: Disregarded payments and the FTC limitation
Adjustments under the disregarded-payment and foreign tax credit rules are often overlooked. This practical framework includes a step-by-step guide and example.
Gray areas of Sec. 1202 warrant regulatory guidance
While recent legislation has further boosted the benefits of the qualified small business stock gain exclusion, official guidance is needed to clarify ambiguities.
Frequently encountered controversy issues in M&A transactions
Procedural issues involving entity change in mergers and acquisitions can be managed by attentiveness and, in many cases, relief provisions.
Application of grandfathering rules under Sec. 162(m) to severance plan payments
The rules hinge on whether a corporation remains obligated since Nov. 2, 2017, to pay an amount under a written binding contract that has not been materially modified after that date.
Dissolving business taxpayers: Selected procedural implications
Critical issues include marking returns as final, determining due dates for final returns, filing Form 966, closing IRS accounts, and handling audits of dissolved entities.
Deductibility of transaction costs incurred by an indirectly acquired entity
Although the IRS has provided guidance on success-based fees, determining which parties are the acquirer and target can be difficult when multiple entities are involved in an M&A.
IRS issues guidance on treaty application to reverse foreign hybrids
The IRS provides guidance on whether these entities qualify under a U.S. federal income tax treaty for relief from the branch profits tax.
Practical tax issues related to qualified reopenings
Treating multiple debt instruments as a single issuance under Sec. 1275 and its regulations can have tax advantages but is often overlooked.
TAX PRACTICE MANAGEMENT
2025 tax software survey
AICPA members in tax practice assess how their return preparation software performed during tax season and offer insights into their procedures.
