Expenses & Deductions
In a Letter Ruling, the IRS concluded that a payment made to terminate a management services agreement did not create an intangible asset or facilitate a transaction.
There are some unique rules for sporting and other live entertainment events under accountable plans.
The IRS has proposed removing the benefits-and-burdens-of-ownership rule for determining which party to a contract manufacturing agreement should get the Sec. 199 domestic production activities deduction.
The IRS has proposed removing the benefits-and-burdens-of-ownership rule for determining which party to a contract manufacturing agreement should get the Sec. 199 domestic production activities deduction.
The new rules govern the Sec. 199 deduction when two taxpayers employ the same employees.
Computer software provided to customers for their direct use while connected to the internet or other public or private communications network, collectively known as online software, is classified as a service provided to customers.
IRS finalized regulations regarding the exception under Sec. 162(m)(4)(c) to the $1 million deduction limitation for compensation paid by publicly held corporations to covered employees.
The IRS issued final regulations regarding the exception under Sec. 162(m)(4)(c) to the $1 million deduction limitation for compensation paid by publicly held corporations to covered employees.
The IRS issued final regulations under Sec. 162(m)(6), which imposes a $500,000 federal income tax deduction limitation for compensation paid by a covered health insurance provider.
Recent regulations provide clarity through enhanced definitions and numerous additional examples to assist taxpayers in determining what are includible as R&E expenditures.
Recent guidance is favorable to taxpayers and simplifies the determination of which milestone payments qualify for the 70% elective safe harbor.
The IRS issued final regulations on which amounts paid or incurred in connection with the development of tangible property, including pilot models, qualify for the Sec. 174 deduction (or amortization) for research and experimental expenditures.
The IRS's primary objective with respect to any contract manufacturing arrangement is ensuring that only one party to the contract can claim to have the benefits and burdens during any qualifying activity. This protects the IRS from being "whipsawed," i.e., being subject to claims by both parties to have the benefits and burdens during a qualifying activity.
The IRS's Large Business and International exam division issued a directive instructing examiners not to challenge a taxpayer's application of the safe harbor to "eligible milestone payments" incurred during the course of a covered transaction if the directive's requirements are satisfied.
Retailers may be eligible to claim a Sec. 199 deduction for advertising revenue derived from producing and distributing printed fliers in cooperation with vendors. This item reviews recent IRS guidance and considers what it might mean for taxpayers that are engaged in cooperative advertising arrangements.
The IRS issued the 2014 inflation adjustments to the depreciation limitations and lease inclusion amounts for certain automobiles under Sec. 280F.
The de minimis safe harbor is one of the areas of the regulations where taxpayers have significant questions. This article answers some of the most frequently asked questions.
The IRS issued final regulations on sales-based royalties and vendor allowance rules.
Directives issued by the IRS Large Business & International Division describe circumstances in which the IRS will not challenge the taxpayer’s position that it has the benefits and burdens of ownership for purposes of the Sec. 199 deduction.
The IRS in September issued proposed regulations clarifying the application of Sec. 174 to the costs to create “pilot models” or prototypes. The proposed rules state that the reason a taxpayer creates a prototype or other product, and not its subsequent sale or use, determines whether it qualifies under Sec. 174.
Qualified business income deduction regs. and other guidance issued