This item discusses what the Inflation Reduction and CHIPS acts could mean for U.S. importers, beginning with the CHIPS Act.
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TOPICS
C Corporation Income Taxation
Pillar 2: Time for US multinational enterprises to act
Large U.S. multinationals can take steps now to assess the potential impact of the global top-up corporate tax system that appears on the verge of being implemented.
Proposed regs. provide rules for repatriation of intangible property
The regulations would terminate the continued application of the Sec. 367(d) annual inclusion in certain cases when intangible property is repatriated to the United States after previously being transferred to a foreign corporation.
Deducting costs that are usually capitalized
Certain environmental cleanup costs, restaurant ‘smallwares,’ and certain vehicle replacement tires have expensing options that business owners may be unaware of.
M&A pitfalls for deferred research expenditures
Treasury and the IRS have issued minimal guidance on current Sec. 174, and future guidance may provide more clarity or different results than what is detailed in this item.
IRS obsoletes 1958 revenue ruling on research and experimental costs
The ruling, which is being obsoleted as of July 31, allowed a taxpayer that used the expense method for research and experimental expenditures to deduct on an amended return research and experimental expenditures the taxpayer did not deduct in prior years.
Proposed regs. identify microcaptive reportable transactions
The IRS has issued proposed regulations that identify certain microcaptive transactions as listed transactions and certain others as transactions of interest.
The CHIPS Act’s semiconductor production credit
This article summarizes the key features of the new Sec. 48D advanced manufacturing investment tax credit and highlights key considerations for manufacturers of semiconductors and semiconductor manufacturing equipment.
Inflation Reduction Act of 2022: Prevailing wage and apprenticeship requirements
This item addresses and summarizes the prevailing wage and apprenticeship requirements of the Inflation Reduction Act, to which credits the labor requirements apply, and taxpayer considerations related to the labor requirements.
A primer on cancellation-of-debt income and exclusions
Various forms of debt workouts and restructurings can trigger COD income, which results in taxable income to the debtor unless specifically excluded under Sec. 108.
Determining compensation deductions in M&A transactions
This item explores three types of compensation paid to employees of the target.
New stock repurchase excise tax
The Inflation Reduction Act, P.L. 117-169, included a new Sec. 4501 that imposes an excise tax on certain repurchases of stock by publicly traded corporations.
The research credit: Funded research
Two recent court cases involving the research credit examine the Sec. 41(d)(4)(H) funded-research exclusion.
Corporate AMT: Unanswered questions about its foreign tax credit
Key issues related to the corporate AMT FTC are unsettled and could have a significant effect on a taxpayer’s corporate AMT liability.
Uncertainties remain in analyzing success-based fees
This item surveys four areas in which taxpayers face uncertainty in analyzing success-based fees.
Taxpayers in disaster areas of 3 states have until Oct. 16 to file returns
Taxpayers in most of California and parts of Alabama and Georgia have had their tax filing and payment deadlines further extended to Oct. 16. The postponement covers a wide variety of returns and taxes.
Final regs. expand company e-filing requirements
Final regulations require certain companies to e-file returns for tax years ending on or after Dec. 31, 2023, and lower the e-filing requirement threshold to 10 returns.
Some corporate taxpayers eligible for IRS CAP pilot on prefiling feedback
The IRS announced on Monday a new pilot phase Compliance Assurance Process (CAP) program called Bridge Plus to provide prefiling return review to some large corporate taxpayers in the Bridge phase.
Determining gross receipts under Sec. 165(g)(3)
This item summarizes some of the relevant authorities and then covers the facts and conclusion in Letter Ruling 202140002.
Marrying ESG initiatives to business tax planning
Companies must focus on how ESG initiatives affect financial performance, market position, and ability to execute strategy, and a key component should be tax policy and planning.
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.
