This item reviews the most significant provisions of the TCJA and CARES Act affecting state corporate tax regimes and discusses state conformity issues that should be addressed by corporate taxpayers.
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TOPICS
C Corporation Income Taxation
Recent changes to the Sec. 179D energy-efficient commercial buildings deduction
The energy efficient commercial buildings deduction under Sec. 179D provides taxpayers with an incentive to make certain commercial building property more energy efficient.
Issues in allocating income under Sec. 384
Although the IRS has addressed several issues in the application of Sec. 384 with letter rulings and other guidance, the Service has yet to come out with comprehensive regulations and, thus, has yet to address several issues with its application.
90-day deadline for filing Tax Court petition in deficiency case is jurisdictional
Deadline for filing a Tax Court petition in a deficiency case is jurisdictional.
New online portal available for businesses to file Forms 1099
Although available to businesses of any size, the IRS expects the new Information Returns Intake System to be especially useful to small businesses that now file paper Forms 1099.
Advance pricing agreements: A realistic option for transfer pricing
In the long run, an agreement with a taxing authority is often a wiser choice than traditional compliance and dispute resolution methods.
FinCEN provides time estimates for compiling beneficial ownership details
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.
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.
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.
