This item outlines a framework and approach for in-house tax professionals to consider when endeavoring to align transfer pricing operations within the broader context of ESG strategy.
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TOPICS
C Corporation Income Taxation
Proposed regulations update, revise consolidated return regulations
New proposed regulations would update the regulations to reflect 50-plus years of statutory changes, remove regulations and certain transition rules that no longer have practical application, and eliminate obsolete or incorrect terms and cross-references.
Credit for increasing research activities in a short tax year
How a short year affects the determination of the credit for increasing research activities under Sec. 41 is often an afterthought for many taxpayers and their tax advisers.
New advanced energy project tax credits under the Inflation Reduction Act
For taxpayers that intend to pursue these credits, it’s a good idea to start planning now and register on
the eXCHANGE portal sooner rathernthan later.
M&A transactions: The value of sell-side tax diligence
This item highlights how sell-side tax diligence can mitigate risks.
AICPA advocates for delay in BOI reporting requirements
Too many businesses are unaware of the beneficial ownership information reporting requirements, which will be a burden for small businesses, the AICPA told Congress.
FDII deduction: Options for determining taxable income
This discussion highlights uncertainties that may arise in determining a corporation’s taxable income for purposes of calculating its foreign-derived intangible income deduction under Sec. 250.
Inflation Reduction Act implications for Sec. 355 distributions
This item examines the implications for distributions described in Sec. 355(a) that follow from the introduction by the Inflation Reduction Act of the stock repurchase excise tax and the corporate alternative minimum tax.
Defining software development costs
Until guidance is issued, taxpayers seeking to determine the fundamental characterization of software costs in order to evaluate what expenditures fall within the scope of new Sec. 174 may find other sources helpful, including those that have historically governed this area.
‘Blocker’ corporations: Considerations for investment fund managers
This item outlines several issues for fund managers to consider as they analyze how to use blocker corporations in their fund structures.
IRS cannot assess Sec. 6038(b) penalties
The IRS does not have statutory authority to assess Sec. 6038(b) penalties.
Including common improvement costs in real property basis
The IRS recently released Rev. Proc. 2023-9, which provides guidance for real estate developers to determine when common improvement costs may be included in the basis of individual units of real property held for sale.
Stock repurchase excise tax reporting and payment delayed by IRS
The IRS says covered corporations will not have to report or pay the new 1% stock repurchase excise tax until it issues forthcoming regulations.
Penalty for underpayment of estimated corporate AMT waived for 2023
The IRS waived the penalty for corporations that did not make estimated payments of corporate AMT for their 2023 tax year, saying the move is “in the interest of sound tax administration.”
The inadvertent-error exception to identifying hedging transactions
If taxpayers make a good-faith effort to comply with the hedge identification rules, then most unidentified hedges would likely have at least an argument for inadvertence.
Taxation of employees’ use of corporate apartments
The use of a corporate apartment as part of business travel generally could be excluded as a working condition fringe benefit, provided substantiation and other requirements are met.
Not all employee parking lots are created equal
An employer will have to make some effort to document that the parking available at an employee parking facility has no value, many employers will find that this burden is worth bearing because it allows deducting the full expenses of operating and maintaining the facility.
State conformity to federal treatment of Sec. 174 R&E costs
This item explores which states likely conform to the amendments to Sec. 174, which states likely decouple from those changes, and the issues raised by conformity to or decoupling from the changes.
Sustainable aviation fuel incentives take off
Tax credits were enacted recently to encourage increased production and use of sustainable aviation fuel in lieu of conventional jet fuel, which produces around 3% of the world’s annual carbon emissions.
Taxing marketplace facilitators: Sourcing issues
This items discusses how various types of revenue earned by marketplace facilitators may be sourced under state laws and regulations.
INDIVIDUALS
Current Developments in Taxation of Individuals: Part 1
This update surveys recent federal tax developments involving individuals, including court cases, rulings, and guidance issued during the six months ending October 2025.
