The explained how the retroactive extension of the Sec. 179 rules operates when applied to qualified real property and how to allocate the portion of gain attributable to the qualified real property upon disposition or to calculate any carryover.
Expenses & Deductions
In proposed regulations , the IRS provided guidance on the treatment under Sec. 174 of R&D expenditures incurred in connection with the development of tangible property, including pilot models.
IRS Reverses Itself on Applying 70% Safe-Harbor Deduction for Success-Based Fees to Certain Milestone Payments
The IRS offers an elective safe harbor to deduct 70% of qualified success-based fees, and while certain “milestone payments” common to acquisition transactions do not qualify for the safe-harbor election, certain “eligible milestone payments” do.
The IRS issued new guidance regarding how to determine which taxpayer is entitled to claim the Sec. 199 domestic production activities deduction in a contract manufacturing arrangement.
The oil and gas industry faces numerous challenges in applying the fact-intensive rules of the so-called repair regulations to costs incurred to repair and maintain property during its service life.
The exception for packaging, repackaging, labeling, or minor assembly activities does not apply to disqualify the taxpayer’s sales receipts from meeting the MPGE requirement under Sec. 199.
Donations of “off-spec” food may not result in a charitable contribution deduction greater than the tax basis of the food inventory because of the difficulty of determining the proper tax basis and FMV for the food.
A recent IRS legal memorandum serves as a reminder to business taxpayers to consider modifying or updating their employee bonus plans to enable a deduction for bonus compensation accrued in the year of the related services, as provided in Rev. Rul. 2011-29.
The Federal Circuit issued a decision reversing and remanding a case to the Court of Federal Claims, which had upheld a LILO transaction.
The IRS has issued proposed regulations on allocating costs to property produced or acquired by a taxpayer for resale.
A business can expense 70% of “success-based fees,” meaning amounts that are contingent on the successful closing of a covered transaction. It is important to remember this safe-harbor election can apply to both sides of the transaction.
Proposed regulations clarify the definition of a reimbursement or other expense allowance arrangement and provide guidance on the applicability of the Sec. 274(e)(3) exception under various circumstances including employer/employee, two-party, and multiparty arrangements.
CCA 201228035 addresses specifically the tax treatment of patronage dividends among related parties and/or controlled groups.
The IRS issued final regulations relating to the disallowance under Sec. 274 of deductions for the use of business aircraft for entertainment (T.D. 9597).
The IRS issued proposed regulations governing the availability of NOL deductions that are attributable to corporate equity reduction transactions.
Tax professionals may be in the best position to support their clients or company in identifying LEED certification costs and determining the appropriate tax treatment as either a current-period expense or a capital expenditure.
This article discusses the purchaser’s perspective of an investment in distressed obligations that are secured by leases on tangible property.
Fund financing can carry with it the potential for unintended tax consequences under Sec. 163(l)’s “disqualified debt” rules.
The IRS issued final regulations relating to the disallowance under Sec. 274 of deductions for the use of business aircraft for entertainment.
The IRS released proposed regulations clarifying which party is subject to the rule that limits the deduction for meals to 50% of the expenses incurred.