Practical ways to enhance operational transfer-pricing processes
For companies that engage in intercompany transactions, being proactive in preparing for disruptions and regulatory changes is essential.
C Corporation Income Taxation
IRS seeks comments on several green energy tax credits
The IRS asks for comments by Dec. 3 on tax credits included in the Inflation Reduction Act, including the commercial clean vehicles provision.
New process provided for anonymous reporting of ERC mills
In a move the AICPA supports, the IRS is providing a new way to make anonymous reports about third-party vendors promoting improper claims for the employee retention credit.
AICPA seeks guidance on corporate alternative minimum tax
The organization’s letter to the IRS and Treasury makes recommendations in five areas to help companies deal with the new tax.
ESG and taxation: A necessary part of a company’s strategic objectives
Businesses are likely to find themselves at a competitive disadvantage if they don’t keep abreast of tax aspects of ESG.
R&D credit claim transition period extended
Taxpayers now have until Jan. 10, 2024, to supply missing information within 45 days of submitting a Sec. 41 research and development credit refund claim under new requirements.
Capital loss rules limit deduction of fees paid to terminate merger agreement
Chief Counsel Advice provides insight to taxpayers planning or negotiating merger-and-acquisition transactions.
Employee retention credit: Navigating the suspension test
This item is intended to help mitigate risk for those still pursuing the ERC by breaking down the suspension test into its core components and shedding light on areas to proceed with caution.
AICPA again critiques new IRS requirements for R&D credits
In a second letter, the AICPA takes issue with broad new documentation requirements for refund claims involving the Sec. 41 credit, outlined in an IRS memo in fall 2021.
Paying dividends as a tax planning strategy
Determining the best way to extract cash from a corporation depends on many factors and assumptions; here is how to evaluate paying compensation vs. dividends.
Congress enacts tax and climate bill
With Senate amendments approved by the House on Friday, the budget reconciliation bill now known as the Inflation Reduction Act will go to the president for his signature.
Key tax provisions in the Senate reconciliation bill
The Inflation Reduction Act passed by the Senate on Sunday includes many tax items, some designed to raise revenue and others to promote various clean energy initiatives.
Deferred compensation deduction and the sale of a business
This item discusses business acquisitions that include assumption of deferred compensation costs and who — buyer or seller (or neither) — has a right to deduct those compensation amounts.
CHIPS and Science Act with semiconductor tax credit passes Congress
The bill now goes to President Joe Biden, who has said he will sign it into law.
Senate deal paves way to reconciliation bill with tax provisions
A federal budget reconciliation bill with tax provisions, including a 15% corporate minimum tax and a variety of tax credits, took a step closer to reality with Sen. Joe Manchin’s agreement to the package’s contents.
Gain recognition agreements: US corporation’s transfer of a foreign corporation followed by the foreign corporation’s disposition of its assets
This item discusses the use of GRAs to defer tax on the outbound transfer of stock to a foreign corporation.
Implications of legislative changes for R&E and software development costs
Modifications to Sec. 174 may affect other areas of taxation which must also be reflected in financial statements and estimated tax payments.
Secondary transfer-pricing adjustments
An inferred secondary transaction may be in the form of a deemed dividend, a deemed capital contribution, or a deemed loan.
A strategy to raise a business’s interest limitation
This article discusses a strategy to allow more interest to be deducted under the limitation involving the strategic adoption of FASB Accounting Standards Codification Topic 606, Revenue From Contracts With Customers.
Transfer pricing and MAP: Common traps for the unwary
There are a number of pitfalls that beset taxpayers seeking to access MAP and to implement MAP resolutions.
