The IRS asks for comments by Dec. 3 on tax credits included in the Inflation Reduction Act, including the commercial clean vehicles provision.
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TOPICS
C Corporation Income Taxation
Deduction of startup expenses
When is a company allowed to report as deductions on a tax return the expenses that have been incurred during the time leading up to getting the doors open for business?
CFCs: US shareholders’ income inclusions
This item clarifies the various categories of income inclusions a U.S. shareholder of a CFC may need to consider to the extent of its current-year earnings and profits or deficits and how to properly report and track any foreign inclusions related to E&P.
Employer-provided and company-owned vehicles
General or special methods of valuing employer-provided vehicles are available for determining the employer’s and employee’s tax treatment of this fringe benefit.
New process provided for anonymous reporting of ERC mills
In a move the AICPA supports, the IRS is providing a new way to make anonymous reports about third-party vendors promoting improper claims for the employee retention credit.
AICPA seeks guidance on corporate alternative minimum tax
The organization’s letter to the IRS and Treasury makes recommendations in five areas to help companies deal with the new tax.
ESG and taxation: A necessary part of a company’s strategic objectives
Businesses are likely to find themselves at a competitive disadvantage if they don’t keep abreast of tax aspects of ESG.
R&D credit claim transition period extended
Taxpayers now have until Jan. 10, 2024, to supply missing information within 45 days of submitting a Sec. 41 research and development credit refund claim under new requirements.
Employee retention credit: Navigating the suspension test
This item is intended to help mitigate risk for those still pursuing the ERC by breaking down the suspension test into its core components and shedding light on areas to proceed with caution.
Capital loss rules limit deduction of fees paid to terminate merger agreement
Chief Counsel Advice provides insight to taxpayers planning or negotiating merger-and-acquisition transactions.
M&A transactions: Deducting accrued liabilities
This item discusses the rules for deducting accrued liabilities in M&A transactions and then provides an illustration by looking at a recent IRS technical advice memorandum.
AICPA again critiques new IRS requirements for R&D credits
In a second letter, the AICPA takes issue with broad new documentation requirements for refund claims involving the Sec. 41 credit, outlined in an IRS memo in fall 2021.
Paying dividends as a tax planning strategy
Determining the best way to extract cash from a corporation depends on many factors and assumptions; here is how to evaluate paying compensation vs. dividends.
Congress enacts tax and climate bill
With Senate amendments approved by the House on Friday, the budget reconciliation bill now known as the Inflation Reduction Act will go to the president for his signature.
Key tax provisions in the Senate reconciliation bill
The Inflation Reduction Act passed by the Senate on Sunday includes many tax items, some designed to raise revenue and others to promote various clean energy initiatives.
Deferred compensation deduction and the sale of a business
This item discusses business acquisitions that include assumption of deferred compensation costs and who — buyer or seller (or neither) — has a right to deduct those compensation amounts.
CHIPS and Science Act with semiconductor tax credit passes Congress
The bill now goes to President Joe Biden, who has said he will sign it into law.
Senate deal paves way to reconciliation bill with tax provisions
A federal budget reconciliation bill with tax provisions, including a 15% corporate minimum tax and a variety of tax credits, took a step closer to reality with Sen. Joe Manchin’s agreement to the package’s contents.
Gain recognition agreements: US corporation’s transfer of a foreign corporation followed by the foreign corporation’s disposition of its assets
This item discusses the use of GRAs to defer tax on the outbound transfer of stock to a foreign corporation.
Implications of legislative changes for R&E and software development costs
Modifications to Sec. 174 may affect other areas of taxation which must also be reflected in financial statements and estimated tax payments.
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.
