Corporations - Deductions

TOPICS / CORPORATIONS

January 31, 2026

Deducting corporate charitable contributions

Some key limitations and
requirements differ from those
with respect to individuals.

November 30, 2025

Two Tax Court rulings expose overvalued conservation easements

In the cases, the Tax Court determined the value of a conservation easement donated to charity using the comparable sales method instead of the discounted-cash-flow method.

October 31, 2025

Comparing and contrasting business tax strategies

Using the correct expensing strategy for items of real and personal property enables taxpayers to obtain the maximum tax benefits.

September 30, 2025

Company’s $1.6 billion ‘break fee’ payment treated as ordinary deduction

A proposed merger agreement’s rights and obligations were in the nature of services, so a fee paid to terminate was not treated as a capital loss, the Tax Court held.

September 30, 2025

IRS ruling clarifies treatment of R&D when computing the FDII deduction

IRS rules research and development services U.S. entities provide to their foreign parent principal company may be characterized entirely as foreign-derived deduction eligible income purposes.

July 18, 2025

Sec. 181: Will 2025 be the series finale?

Sec. 181 expensing of costs of qualified film, television, and theatrical productions gives producers cause to cheer, but the curtain may be falling on this temporary provision.

March 31, 2025

IRS increases scrutiny of business aircraft use

Businesses that own, lease, or charter aircraft should prepare for increased IRS scrutiny by closely reviewing their compliance with applicable tax provisions.

March 31, 2025

A closer look at the costs of borrowing

Comparison of the accounting and tax treatment of interest expense may reveal crucial differences and lead to best practices for managing it.

February 28, 2025

On DRD, the IRS seeks to have its cake and eat it too

The plain language of Sec. 245A disallowed a dividends-received deduction for a controlled foreign corporation, the IRS Office of Chief Counsel held, contrary to the Service’s argument in a recent Tax Court case.

February 28, 2025

Payments for law violation are not deductible restitution

A recent Chief Counsel Advice memo determined that the deductions were disallowed as fines or penalties under Sec. 162(f).

January 15, 2025

Prop. regs. address expanded annual compensation deduction limitation

The regulations provide guidance on determining who is one of the “five highest compensated employees” under Sec. 162(m)(3)(C).

January 1, 2025

Taxpayer may not deduct penalties imposed for violating a law

An IRS technical advice memorandum examines a taxpayer’s fines and penalties paid to a state agency.

December 1, 2024

Burden of proof: The shoebox method and 9-martini lunch

When taxpayers claim deductions for business expenses, they must meet their burden of proof with proper recordkeeping.

December 1, 2024

Planning opportunities: Sec. 179 expensing vs. bonus depreciation

As bonus depreciation phases out, practitioners need to consider Sec. 179 expensing to maximize deductions on fixed-asset purchases.

November 1, 2024

Sec. 245A dividends-received deduction allowed for Sec. 78 dividend

In Varian Medical Systems Inc., the Tax Court found the company eligible for the deduction for 2018 despite a disqualifying change in Sec. 78, due a mismatch between the change’s effective date versus the effective date of then-new Sec. 245A.

August 1, 2024

Advances between affiliated entities: An uphill but winnable battle for loan characterization

Whether a purported loan between affiliated or commonly controlled entities will be recharacterized as equity can depend on the 13 Mixon factors.

August 1, 2024

Sec. 163(j) planning considerations

Businesses can explore several options to mitigate the interest deduction limitation under the Tax Cuts and Jobs Act.

July 1, 2024

Electing the UNICAP historic absorption ratio under the modified simplified production method

To avoid contending with the complex and time-consuming calculations of the uniform capitalization rules under Sec. 263A, taxpayers may want to consider electing the historic absorption ratio with this method.

June 18, 2024

Regs. cover green energy incentive wage and apprenticeship requirements

Under new final regulations issued by the IRS, taxpayers can generally increase the base amount of certain credits or deductions by five times when they meet prevailing wage and apprenticeship requirements.

May 1, 2024