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.
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TOPICS
C Corporation Income Taxation
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.
The research credit: Using statistical sampling
This item discusses the Sec. 41 research credit and how statistical sampling can be used to efficiently satisfy the fourpart test that governs whether research activities qualify for the credit.
Letter ruling provides clarity on Sec. 1202 definition of brokerage services
In determining whether a corporation was engaged in brokerage services, the IRS ignored definitions of the term in other areas of the tax law and instead resorted solely to the plain meaning of the term as found in a dictionary.
IRS issues procedures for employee status determinations
Prior guidance on Tax Court jurisdiction over IRS determinations of employee vs. independent contractor status is modified and superseded.
New R&D credit documentation requirements clarified
Starting Jan. 10, a Sec. 41 credit claimed on an amended return must include specific information.
What’s new for 2022 in federal taxes
A law change and some regulations take effect while an array of provisions expire.
Deferral of penalties for failure to timely deposit employment taxes
The IRS determined that a failure to deposit any portion of the federal employment taxes deferred by the CARES Act by the applicable installment due date will result in a penalty.
Voluntary carbon offsets: The evolution of a business expense
This article discusses the disclosure and reporting of VCOs and whether VCOs should be treated as deductible ordinary and necessary business expenses, capitalizable expenses, deductible charitable contributions, or nondeductible expenses.
Identifying corporations subject to the at-risk rules
The at-risk rules limit the losses allowed to closely held C corporations on certain investments, testing each separate activity to determine if the corporation is at risk for that activity.
Standard mileage rates to go up in 2022
The IRS issued the annual update of the mileage rate taxpayers may use to compute their deductible automobile costs.
Decoding the Senate Finance Committee’s Build Back Better text
The Senate Finance Committee has released language for its portion of the reconciliation bill, which some lawmakers would like to pass before Christmas. Here’s what you need to know about the timeline and the bill, which includes several key tax provisions.
Senate Finance Committee releases tax provisions of Build Back Better Act
The Senate Finance Committee’s text includes changes from the House’s version of the bill, including a removal of the House’s increase in the SALT deduction cap.
Early sunset of the employee retention credit gets penalty relief
The IRS describes how employers may avoid failure-to-pay and failure-to-deposit penalties for ERC claimed or anticipated in the fourth quarter but eliminated by the Infrastructure Act.
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.
