A common method of resolving intercompany debt can entail ambiguity when a foreign subsidiary is involved, due to a dearth of regulatory guidance.
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Tax Computation
Tax implications in the automotive industry: The core of remanufacturing
Remanufactured “cores,” or used vehicle parts, are essential to the automotive industry but present distinct special tax and accounting considerations.
Lenders’ tax consequences of foreclosure
Third-party creditors holding defaulting loans need to understand calculating gain or loss and whether it is ordinary or capital in foreclosure and deed-in-lieu of foreclosure proceedings.
Dual consolidated losses: Recapture considerations
An interesting issue can arise when a corporation must recapture dual consolidated losses on the sale of a foreign entity.
Including common improvement costs in real property basis
The IRS recently released Rev. Proc. 2023-9, which provides guidance for real estate developers to determine when common improvement costs may be included in the basis of individual units of real property held for sale.
The inadvertent-error exception to identifying hedging transactions
If taxpayers make a good-faith effort to comply with the hedge identification rules, then most unidentified hedges would likely have at least an argument for inadvertence.
Pillar 2: Time for US multinational enterprises to act
Large U.S. multinationals can take steps now to assess the potential impact of the global top-up corporate tax system that appears on the verge of being implemented.
Determining gross receipts under Sec. 165(g)(3)
This item summarizes some of the relevant authorities and then covers the facts and conclusion in Letter Ruling 202140002.
Sec. 987 foreign currency regulations applicability date extended again
On Aug. 15, 2022, the IRS announced that it intends to defer by one more year the applicability date of certain foreign currency regulations under Sec. 987.
IRS rules on cancellation of debt of a disregarded entity
Taxpayers should strongly consider these letter rulings when trying to determine whether they want to structure a borrowing with a regarded entity as the legal borrower or whether they prefer to have a DRE be the legal borrower of the debt.
Top 10 business income tax planning ideas for the pandemic
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.
Elective capitalization as a TCJA planning tool
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.
Proposed bonus depreciation regs. provide answers, create new questions
The proposed regulations clarify the elections available to all taxpayers regarding bonus depreciation.
Statistical sampling and resulting allocations under fixed-asset studies
This item discusses a methodology to sample expenditures by reviewing amounts capitalized for
book purposes and to determine the extent to which they should be classified as tangible personal property or expensed for tax purposes.
Bonus Depreciation: The PATH Act and Beyond
In addition to extending bonus depreciation and phasing out the bonus rate, the PATH Act made several changes to the types of eligible property
under Sec. 168(k)(2).
Bonus Depreciation After the PATH Act
Congress made a notable change to the definition of qualifying property for bonus depreciation purposes.
Tax Planning Businesses Can Do Before Year End
Here are some suggestions to help business clients reduce 2015 taxes by accelerating deductions into this year and delaying income until next year.
“Substantially Complete” Buildings Eligible for GO Zone Depreciation
In Stine, LLC, No. 2:13-cv-03224 (W.D. La. 1/27/15), a retailer’s store buildings were considered “placed in service” for federal tax depreciation purposes when they were “substantially complete” rather than when they subsequently were “open for business” resulting in the taxpayer’s being able to take an accelerated depreciation deduction for the buildings. This decision highlights the importance of properly identifying an asset’s placed-in-service date.
Cost-Segregation Studies and the Impact of the Tangible Property Regulations
This item highlights several important aspects of the final tangible property regulations and related transition guidance that may affect cost-segregation studies and resulting changes in accounting methods.
GAAs Are a Valuable Planning Option for Tangible Property Depreciation
General asset accounts provide a valuable simplification tool for tracking tangible assets and present some tax planning opportunities.
employee benefits & pensions
Profits interests: The most tax-efficient equity grant to employees
By granting them a profits interest, entities taxed as partnerships can reward employees with equity. Mistakes, however, could cause challenges from taxing authorities.
