IRS official: New R&D credit documentation applies to amended returns
The deputy commissioner of the IRS Large Business and International Division hears AICPA tax committee’s feedback on new requirements.
C Corporation Income Taxation
Tax provisions in the Build Back Better act
The Build Back Better Act contains a large number of tax provisions, ranging from an extension of the advance child tax credit, to a wide variety of green energy tax incentives, and a minimum tax on corporations.
Infrastructure bill tax provisions include ERC termination
The infrastructure bill that passed the House on Friday and is headed to President Joe Biden’s desk will terminate the employee retention credit early and require broker reporting of cryptoasset transfers.
Corporation not covered by economic hardship exception
The economic hardship exception to a levy does not apply to corporations.
Certification deadline extended for work opportunity tax credit
Certain employers have until Nov. 8 to submit a required worker certification request to a designated local agency for purposes of the work opportunity credit.
New safe harbor for ERC gross-receipts calculation
Under the safe harbor, an employer can exclude certain amounts received from other coronavirus economic relief programs in determining whether it qualifies for the employee retention credit based on a decline in gross receipts.
Beware of IRS initiatives against microcaptive insurance arrangements
Microcaptive insurance arrangements have been vigorously scrutinized recently by the IRS.
IRS memo illustrates application of Sec. 263 to amounts paid to acquire or create intangibles
The memo provides an analysis of the capitalization of amounts paid to acquire or create intangibles, providing insight into capital expenditures under Sec. 263 and trade or business expenses under Sec. 162, clarifying capitalizing vs. expensing.
AICPA requests LIFO safe harbor
Global supply chain problems caused by the COVID-19 pandemic have made it difficult for US companies to replace inventories, potentially subjecting them to additional taxable income. The AICPA has requested relief under Sec. 473.
Qualified small business stock exclusion: Who’s eligible?
This discussion explores the question of how to determine whether a company is engaged in a qualified trade or business.
Automatic procedures to change a CFC’s depreciation method
The IRS issued Rev. Proc. 2021-26, which contains procedures for certain foreign corporations to obtain automatic consent to change their methods of accounting for depreciation to the alternative depreciation system.
IRS amplifies and updates ERC for second half of 2021
New guidance clarifies the application of the credit to “recovery startup businesses” and the treatment of wages paid to majority owners and their spouses.
Foreign notional interest regimes may hinder deductions of US subsidiaries
Inbound structures involving interest or royalty payments by U.S. subsidiaries to foreign affiliates may trigger anti-avoidance rules where the foreign affiliates operate in countries that have notional interest deduction tax regimes.
Capitalized improvements vs. deductible repairs
The distinctions among betterments, improvements, routine maintenance, and the effects of normal wear and tear are key to determining whether building expenditures are currently deductible or must be capitalized.
Foreign taxes on PTEP can provide additional foreign tax credits
This item focuses on the potential increase in the Sec. 904(a) foreign tax credit limitation when PTEP is distributed by a CFC to its corporate “U.S. shareholder.”
Naked credits and the interest expense limitation
New regulations providing guidance on the application of the Sec. 163(j) interest expense limitation may change how some companies calculate their naked credit.
IRS guidance denies ERC for most majority owners’ wages
The IRS’s release of Notice 2021-49 provides employers with additional guidance on issues of the employee retention credit.
Final regs. issued on qualified improvement property under FDII, GILTI
Final regulations clarify the treatment of qualified improvement property in FDII and GILTI, and foreign tax credit transition rules address post-2017 NOL carrybacks to pre-2018 tax years.
Ways and Means releases list of tax provisions for budget bill
The proposal would raise tax rates for corporations and individuals and make many other changes to the Internal Revenue Code.
E&P planning opportunities when acquiring subsidiaries
The tax impact on future shareholder distributions should be considered prior to liquidating an acquired subsidiary.
