Two Code provisions, Sec. 162 and Sec. 165, offer a potential deduction for a taxpayer who has property that has been damaged by a casualty.
Deductions
Sec. 199 deduction for qualified film and the IRS compliance campaign approach
The IRS has created an LB&I compliance campaign that affects multichannel video programming distributors and television broadcasters.
IRS memorandum provides clarity on treatment of debt-issuance costs
The IRS concluded that a taxpayer could deduct the unamortized debt-issuance costs related to its existing debt upon its exchange for new debt.
Items and factors to consider in setting reasonable compensation
All companies should maintain supporting documentation for payments.
How tax overhaul would change business taxes
The tax reform bill that Congress is expected to vote on this week contains numerous changes that will affect businesses large and small.
House bill features many business tax changes
The House tax reform bill contains a large number of proposed changes that would affect businesses.
Recommendations for charitable contributions made by businesses
This column discusses the treatment and classification of contributions made by businesses.
Fuel blending and the Sec. 199 deduction
This column discusses whether fuel blending may be
treated as a domestic production activity for purposes of the DPAD deduction.
Tax Court: Sports team allowed 100% meal deduction when traveling for road games
The U.S. Tax Court held that a professional hockey team could deduct the cost of meals provided to players and other employees at the team’s hotel
while traveling for games.
Boston Bruins can deduct 100% of cost of certain pregame meals
The U.S. Tax Court held that pregame meals provided to players and personnel before away games qualify as a de minimis fringe benefit.
Deducting startup and expansion costs
Certain business expenses incurred to start or expand a business can be currently deducted.
Tax Court allows full meal deduction for NHL team’s away games
Pregame meals provided to Boston Bruins players and personnel before away games qualify as a de minimis fringe benefit.
Boston Bruins can deduct full cost of meals for team’s away games
The Tax Court held that the owners of the Boston Bruins could deduct the full cost of their team’s pregame meals for away games as a de minimis fringe benefit.
IRS focuses on Sec. 199 for cable, satellite, and broadcast TV
Among the first wave of examination “campaigns” announced by the IRS’s LB&I is the application of the Sec. 199 domestic production activities deduction to “multi-channel video programming distributors.”
IRS Does Not Acquiesce to Treatment of Discounts in Giant Eagle
Taxpayers should expect to see continued controversy
regarding when a liability is fixed for customer discounts.
IRS Clarifies Definition of “Construction of Real Property” for Purposes of Sec. 199
The IRS determined a taxpayer’s substantial renovation, construction, and erection of certain
property qualified as the construction of real property under Sec. 199.
Tax Court Finds Compensation Reasonable, Rejects IRS Attempt to Modify Independent-Investor Test
In this case, compensation paid by a closely held corporation was reasonable and therefore deductible.
Dental Practice’s Management Fees Were Not Ordinary and Necessary Business Expenses
The fees were unnecessary because the taxpayer did not provide proof to show that any services were actually performed in exchange for the fees.
Documenting Deductible Transaction Costs for Acquisitive Transactions
This item discusses the ability of a target in a Sec. 338(h)(10) transaction to use the safe-harbor election provided by Rev. Proc.
2011-29.
Charitable Donations of Food Inventory
A recent change in the law makes it easier for taxpayers to claim charitable deductions for food products donated to charity.
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.