The Build Back Better Act contains a large number of tax provisions, ranging from an extension of the advance child tax credit, to a wide variety of green energy tax incentives, and a minimum tax on corporations.
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TOPICS
C Corporation Income Taxation
Infrastructure bill tax provisions include ERC termination
The infrastructure bill that passed the House on Friday and is headed to President Joe Biden’s desk will terminate the employee retention credit early and require broker reporting of cryptoasset transfers.
Certification deadline extended for work opportunity tax credit
Certain employers have until Nov. 8 to submit a required worker certification request to a designated local agency for purposes of the work opportunity credit.
New safe harbor for ERC gross-receipts calculation
Under the safe harbor, an employer can exclude certain amounts received from other coronavirus economic relief programs in determining whether it qualifies for the employee retention credit based on a decline in gross receipts.
IRS memo illustrates application of Sec. 263 to amounts paid to acquire or create intangibles
The memo provides an analysis of the capitalization of amounts paid to acquire or create intangibles, providing insight into capital expenditures under Sec. 263 and trade or business expenses under Sec. 162, clarifying capitalizing vs. expensing.
Qualified small business stock exclusion: Who’s eligible?
This discussion explores the question of how to determine whether a company is engaged in a qualified trade or business.
AICPA requests LIFO safe harbor
Global supply chain problems caused by the COVID-19 pandemic have made it difficult for US companies to replace inventories, potentially subjecting them to additional taxable income. The AICPA has requested relief under Sec. 473.
Beware of IRS initiatives against microcaptive insurance arrangements
Microcaptive insurance arrangements have been vigorously scrutinized recently by the IRS.
Corporation not covered by economic hardship exception
The economic hardship exception to a levy does not apply to corporations.
Foreign taxes on PTEP can provide additional foreign tax credits
This item focuses on the potential increase in the Sec. 904(a) foreign tax credit limitation when PTEP
is distributed by a CFC to its corporate “U.S. shareholder.”
Automatic procedures to change a CFC’s depreciation method
The IRS issued Rev. Proc. 2021-26, which contains procedures for certain foreign corporations to obtain automatic consent to change their methods of accounting for depreciation to the alternative depreciation system.
Capitalized improvements vs. deductible repairs
The distinctions among betterments, improvements, routine maintenance, and the effects of normal wear and tear are key to determining whether building expenditures are currently deductible or must be capitalized.
IRS amplifies and updates ERC for second half of 2021
New guidance clarifies the application of the credit to “recovery startup businesses” and the treatment of wages paid to majority owners and their spouses.
Foreign notional interest regimes may hinder deductions of US subsidiaries
Inbound structures involving interest or royalty
payments by U.S. subsidiaries to foreign affiliates may trigger anti-avoidance rules where the foreign affiliates operate in countries that have notional interest deduction tax regimes.
Naked credits and the interest expense limitation
New regulations providing guidance on the application of the Sec. 163(j) interest expense limitation may change how some companies calculate their naked credit.
IRS guidance denies ERC for most majority owners’ wages
The IRS’s release of Notice 2021-49 provides employers with additional guidance on issues of the employee retention credit.
Final regs. issued on qualified improvement property under FDII, GILTI
Final regulations clarify the treatment of qualified improvement property in FDII and GILTI, and foreign tax credit transition rules address post-2017 NOL carrybacks to pre-2018 tax years.
Ways and Means releases list of tax provisions for budget bill
The proposal would raise tax rates for corporations and individuals and make many other changes to the Internal Revenue Code.
The potential for lost benefits of Up-Cs in a Sec. 280E environment
This item summarizes the traditional Up-C/TRA arrangement and addresses the impact of Sec. 280E on the Up-C/TRA structure.
FAQs address ARPA credits
The IRS has posted two sets of FAQs that explain changes to the child and dependent care credit and to the sick and family leave credits made by the American Rescue Plan 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.
