In a letter dated Aug. 4, 2020, the AICPA joined over 170 organizations to urge Congress to “include a technical correction addressing the tax treatment of loan forgiveness under the Paycheck Protection Program (PPP)” in its next round of legislation addressing the coronavirus pandemic.
This discussion focuses on how the AMT rules impact the NOL rules under the CARES Act.
Refund claim for overpayment caused by credit is attributable to net operating loss for purposes of the Sec. 6511(d)(2) limitation period.
Foresight of the potential state tax implications of an F reorganization will allow a seller to evaluate the lesser-known hazards.
A host of new issues have arisen in merger-and-acquisition transactions because of the unpredictable business environment caused by changes in the law in response to the COVID-19 pandemic. This article discusses some of the pandemic-related concerns buyers and sellers will have in M&A transactions, and the additional safeguards and procedures participants should take to deal with these concerns.
The IRS issued regulations explaining the allowance of deductions for certain fines and penalties under Sec. 162(f) as amended by the law known as the Tax Cuts and Jobs Act.
The TCJA introduced a new export tax incentive — the Sec. 250 deduction for foreign-derived intangible income — that is available only to domestic C corporations.
The IRS has issued final regulations addressing when certain related-party interests in corporations should be treated as stock vs. debt.
The IRS issued final regulations under the global intangible low-taxed income (GILTI) rules on the treatment of income subject to a high rate of foreign tax. At the same time, the IRS issued proposed rules conforming the GILTI high-tax exception rules with the Subpart F high-tax exception.
The IRS issued proposed and temporary regulations explaining how consolidated groups should apply the changes to the net operating loss rules enacted by the CARES Act.
The CARES Act creates several opportunities for businesses to shore up cash flow.
This discussion explores the step transaction doctrine and the facts, analysis, and rulings of Rev. Ruls. 2001-46 and 2008-25, then analyzes the rulings to illustrate how form can make a difference in multistep transactions.
The IRS issued guidance clarifying that a deduction is disallowed for expenses for payroll costs, mortgage interest, rent, utilities, and other interest on debt obligations to the extent they are being reimbursed by loans forgiven under the Paycheck Protection Program.
This article summarizes business and individual tax provisions of the CARES Act, emergency legislation designed to speed relief to employers and individuals who are struggling due to the COVID- 19 pandemic.
Closely held corporations must test whether the personal holding company tax applies and what measures to take to avoid it.
Right now, some basic tax planning ideas can make a significant difference in reducing income tax, thereby increasing cash flow and even creating tax refund opportunities.
The IRS issued proposed regulations implementing changes to Sec. 274 that disallow a deduction for the expense of any Sec. 132(f) qualified transportation fringe provided to an employee, effective for amounts paid or incurred after Dec. 31, 2017.
The IRS announced that employers may make donations this year to charitable organizations that provide relief to COVID-19 pandemic victims in exchange for personal leave that their employees forgo.
No deduction may be claimed for FDIC premiums paid or accrued by taxpayers with total consolidated assets of $50 billion or greater.
Taxpayers whose overall tax position in a given year would benefit from accelerating gross income or from converting current deductions into capital expenditures should consider the elective capitalization provisions of Sec. 266.