The regulations define the term “substantially all,” the definition of which was reserved in the earlier proposed regulations issued in October 2018.
One of the requirements of Sec. 1202 is that the issuing corporation must be a qualified small business as of the date of issuance and immediately after the issuance.
The IRS finalized proposed regulations issued last August on the new transition tax, which generally taxes the accumulated post-1986 deferred foreign income of a corporation.
The IRS announced that it is reviewing its approach to the active trade or business requirement that must be met for a five-year period for a business to qualify for a tax-free spinoff under Sec. 355 and, as a result, is suspending two revenue rulings, Rev. Ruls. 57-464 and 57-492, in which it previously ruled on the topic.
This article discusses several key factors that CPAs and benefit plan advisers should consider to help successfully integrate plans during a merger or acquisition.
With their prospects for deferral or even exclusion of gains from certain investments in them, the newly created qualified opportunity zones offer an intriguing tax planning option for investors and a potential boon for distressed communities.
The IRS issued proposed regulations on the business interest expense limitation in Sec. 163(j), which was amended by the law known as the Tax Cuts and Jobs Act.
Failure to properly complete all required fields on Form 8283, including the donor’s cost or other basis, could jeopardize the entire deduction with respect to the donated property.
The proposed regulations clarify the elections available to all taxpayers regarding bonus depreciation.
This article offers guidance on maximizing the use of corporate state NOLs, recording deferred tax assets and valuation allowances for them, and incorporating their value in the pricing of M&A transactions.
Taxpayers should carefully review the proposed regulations for relevant limitations and be mindful of how future guidance may affect their investments.
The IRS concluded that a derivative that referenced a stock index was “substantially similar or related property” to the stock of an exchange-traded fund that held the components of the index.
The IRS concluded that a taxpayer was required to capitalize 100% of an investment banking fee because it failed to satisfy the documentation requirement for success-based fees under Regs. Sec. 1.263(a)-5.
Recent events should give taxpayers greater confidence to include pilot model expenses as Sec. 74 expenses and R&D supply costs.
The Sec. 162(m) grandfather rule provides multiple opportunities outside of the exemption for performance-based compensation.
The IRS released advice that concluded that an accrual-based taxpayer was entitled to deduct quarterly commitment fees paid related to its revolving credit agreement.
In a changing landscape, U.S. C corporation multinationals should consider reevaluating their value chain.
This item provides an overview of the Sec. 958 constructive ownership rules, explores the “glitch" and its consequences, and discusses planning options to mitigate the negative effects.
This article discusses the modifications made to Sec. 174 and Sec. 41, which will affect taxpayers’ R&D tax credit claims for tax years after Dec. 31, 2021.
Sec. 856(n)(1)(a) specifies that passive foreign exchange gain (as defined in Sec. 856(n)(3)) for any tax year is not gross income for purposes of Sec. 856(c)(2).