The tax impact on future shareholder distributions should be considered prior to liquidating an acquired subsidiary.
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TOPICS
C Corporation Income Taxation
Interruption of LIFO inventories due to COVID-19 and Sec. 473 relief
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.
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.
Guidance on claiming the ERC for third and fourth quarters 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-derived intangible income: Issues and practical strategies
This article discusses issues that have evolved around FDII where there has been little guidance and outlines ways to better take advantage of the FDII regime.
The current state of evolution of cryptoasset taxation
Recently released IRS Chief Counsel Advice targeted at the BTC/BCH hard fork also provides insight into how the IRS may evaluate more complex cryptoasset transactions.
PFIC considerations for non-US SPACs
As SPAC activity has increased, non-U.S.-domiciled
SPACs have become more prevalent and carry major U.S. tax-compliance ramifications due to their potential treatment as a PFIC for U.S. investors.
Budget and Greenbook detail Biden’s tax proposals
The proposed $6 trillion fiscal year 2022 budget unveiled by the Biden Administration includes a host of tax items, including proposals to raise the corporate tax rate, raise the top tax rate for high-income individuals, limit like-kind exchanges, and make permanent recent temporary changes to various tax credits.
Business meal deductions after the TCJA
This article discusses the history of the deduction of business meal expenses and the new rules under the TCJA and the regulations and provides a framework for documenting and substantiating the deduction.
Sec. 199A and Subchapter M: RICs vs. REITs
Sec. 199A, may create a potential difference in how the same type of income is taxed to shareholders of RICs and REITs and therefore offers an opportunity for fund managers.
Superseding returns and statutes of limitation
CARES Act provisions on net operating losses place new spotlight on the effect of filing superseding returns.
Safe harbor allows 2020 PPP expenses to be deducted in 2021
The IRS issued guidance on a safe harbor permitting qualifying taxpayers who have PPP loans, who did not deduct expenses related to those loans paid or incurred in 2020 on their 2020 returns, to deduct the expenses on their returns for 2021.
Penalty relief for Forms 5471, 5472, and 8865
Various options are available for mitigating penalties for noncompliance with foreign return filing requirements.
When does it make sense to elect out of the installment method?
Reporting gain in the year of a sale rather than with installments over time may become more attractive as proposals for higher capital gains tax rates gain traction. This article weighs the pros and cons.
Virtual currency update
Treasury takes a more aggressive stance on reporting of virtual currency transactions.
Penalty relief for payroll tax deposits allows immediate use of pandemic credits
The IRS provided for penalty relief under Sec. 6656 for an employer’s failure to timely deposit certain employment taxes with the IRS to allow employers to immediately take advantage of various credits enacted in response to the COVID-19 pandemic.
Generic drug manufacturer can deduct patent infringement suit expenses
Legal expenses for notice letters required as part of
an application to the FDA for permission to produce and market generic drugs are capitalizable, but legal expenses for patent litigation as a result of certain certifications made during the approval process are deductible.
Critical valuation issues that arise in common corporate transactions
This discussion provides an overview of some of the critical valuation issues that arise in Secs. 351, 332, and 338.
Accounting method planning to increase taxable income
In certain circumstances, taxpayers may benefit from increasing taxable income; accounting method planning can help taxpayers achieve that objective.
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.
