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.
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TOPICS
C Corporation Income Taxation
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.
Secondary transfer-pricing adjustments
An inferred secondary transaction may be in the form of a deemed dividend, a deemed capital contribution, or a deemed loan.
Transfer pricing and MAP: Common traps for the unwary
There are a number of pitfalls that beset taxpayers seeking to access MAP and to implement MAP resolutions.
A strategy to raise a business’s interest limitation
This article discusses a strategy to allow more interest to be deducted under the limitation involving the strategic adoption of FASB Accounting Standards Codification Topic 606, Revenue From Contracts With Customers.
Maximizing the benefits of general business tax credits
The Sec. 196 deduction for unused business credits is available both where the credit carryforward period expires and when a taxpayer dies or ceases to exist.
Customs duty refunds on transfer-pricing adjustments
This discussion explores key considerations to keep in mind for claiming customs duty refunds on transfer-pricing adjustments.
Considerations for multinationals with US and Maltese operations
This discussion explores certain issues that multinationals should consider when deciding whether to use Malta as part of their worldwide operations.
Freezing stock value with a corporate recapitalization
A corporate recapitalization can freeze the value of the owner’s stock, potentially reducing the owner’s estate tax liability by removing future appreciation in the value of stock from the owner’s estate.
Differences between transfer pricing and financial reporting valuations
The difference in valuation standards between financial reporting and transfer pricing leads to the use of different valuation methods for each. This may significantly affect the valuation of the asset for transfer-pricing purposes.
A resurgence of the accumulated earnings tax?
A nondividend payment by a corporation out of its surplus earnings may be viewed by the IRS as evidence of a purpose to avoid shareholder-level income tax.
An early 21st century history of IRS efforts to police the R&D credit
The IRS has attempted to review and audit R&D credit claims through various techniques and strategies over the years, and the FAA harks back to recordation requirements of the late 1990s and early 2000s.
Reinstatement of the Superfund excise tax
This item addresses and summarizes the key provisions of the Infrastructure Act as it pertains to the reinstated Superfund tax, along with some taxpayer considerations related to the tax.
Biden proposes higher corporate tax rate, 20% billionaire minimum tax
Fiscal 2023 tax provisions also would increase IRS funding, encourage domestic business investments, and repeal many fossil fuel tax preferences.
Research credit refund claims: New documentation requirements
A Chief Counsel memorandum advises that taxpayers must provide additional information to make a valid Sec. 41 research credit refund claim on an amended tax return.
Shareholder’s forgiveness of insolvent corporation’s debt
A debt cancellation or forgiveness by a corporation’s shareholder is a common transaction, but some critical tax consequences are uncertain including
the determination of any income from the cancellation of debtunder certain circumstances.
IRS rules on cancellation of debt of a disregarded entity
Taxpayers should strongly consider these letter rulings when trying to determine whether they want to structure a borrowing with a regarded entity as the legal borrower or whether they prefer to have a DRE be the legal borrower of the debt.
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.
