FinCEN estimates that most companies will have a simple structure that will require 90 minutes per response, but complex entry filings will require much more time.
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TOPICS
C Corporation Income Taxation
FinCEN proposes rules about access to beneficial ownership information
Proposed regulations under the Corporate Transparency Act address protocols for access to beneficial owner information by authorized recipients.
Chief Counsel memo clarifies the assessment period in multiyear Sec. 332 liquidations
A recent IRS Chief Counsel memo clarifies the assessment limitation period in multiyear Sec. 332(b) liquidations.
Inflation Reduction Act includes 15% corporate minimum tax on book income
For applicable corporations that report over $1 billion in profits to shareholders, the act includes a 15% corporate alternative minimum tax based on book income.
Memo removes IRS procedural requirements for economic substance arguments
The IRS no longer requires examiners to follow a four-step process for determining whether a transaction complies with the economic substance doctrine before a penalty can be asserted under Secs. 6662(b)(6) and 6662(i).
Sec. 987 foreign currency regulations applicability date extended again
On Aug. 15, 2022, the IRS announced that it intends to defer by one more year the applicability date of certain foreign currency regulations under Sec. 987.
The Inflation Reduction Act’s energy- and climate-related tax provisions
This article provides a high-level summary of the changes and discusses their implications for taxpayers.
Despite unanswered questions, Tax Court ends long-running case
The Tax Court enters a new decision in a case despite an ambiguous appellate court mandate
Tax practitioner issues related to Sec. 1202 exclusion reporting
The lack of guidance and regulations and the unwillingness of some companies to provide information to shareholders places taxpayers and tax practitioners in a difficult situation.
Practical ways to enhance operational transfer-pricing processes
For companies that engage in intercompany transactions, being proactive in preparing for disruptions and regulatory changes is essential.
IRS seeks comments on several green energy tax credits
The IRS asks for comments by Dec. 3 on tax credits included in the Inflation Reduction Act, including the commercial clean vehicles provision.
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.
TAX PRACTICE MANAGEMENT
2025 tax software survey
AICPA members in tax practice assess how their return preparation software performed during tax season and offer insights into their procedures.
