The IRS finalized rules disallowing deductions for most business entertainment expenses and distinguishing them from business food and beverage expenses that remain deductible.
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TOPICS
C Corporation Income Taxation
The built-in gains tax
The built-in gains tax applies to C corporations that make an S corporation election, and it can
be assessed during the five-year period starting with the first tax year for which the S election is effective.
Expenses funded with PPP loans
This item discusses tax issues related to the forgiveness of PPP loans.
How to treat foreign tax credits
The IRS issued final and proposed regulations covering a variety of issues involving deductions and credits for foreign taxes.
IRS doubles down on nondeductibility of PPP-funded expenses
The IRS issued guidance for taxpayers who pay otherwise deductible expenses with PPP loan funds, stating that even if the payment and PPP loan forgiveness happen in different tax years, the expenses are not deductible.
Blockchain technology firms’ transfer-pricing issues
This article presents some of the transfer-pricing considerations that blockchain companies must address as they grow and expand across borders.
Qualified transportation fringe disallowance
The article discusses the June 2020 proposed regulations and how they compare to the prior guidance in Notice 2018-99.
Consolidated group NOL rules are finalized
The IRS finalized regulations governing the treatment of net operating losses by consolidated groups after recent legislation changed the rules.
Several states provide one-month filing relief for corporate deadlines
With the Oct. 15 corporate tax filing deadline looming and the global pandemic still affecting taxpayers and practitioners, several states have provided one-month filing relief for their corporate Oct. 15 deadlines.
IRS releases final rules on business meals and entertainment
The IRS finalized rules implementing provisions of the law known as the Tax Cuts and Jobs Act, disallowing deductions for most business entertainment expenses and distinguishing them from business food and beverage expenses that remain deductible.
Legal entity rationalization and simplification
The process of a legal entity rationalization or simplification of a legal organizational chart has numerous moving and interrelated components that need to be considered during each step of the
process.
Summary of tax rules for liquidating corporations
If a corporation is terminating or intending to convert to an LLC taxed as a partnership, the liquidation regulations will apply.
IRS issues more rules on GILTI tax
The IRS issued final regulations under the GILTI rules on the treatment of income subject to a high rate of foreign tax. At the same time, the IRS issued proposed rules conforming the GILTI high-tax exception rules with the Subpart F high-tax exception.
Incorporating a single-owner business
Single-member LLCs and sole proprietorships must
consider several unique issues when choosing to incorporate — including the tax consequences of
transferring, or not transferring, assets into the newly formed corporation.
State implications of Sec. 163(j) under TCJA and CARES Act
States’ approaches to TCJA and CARES Act conformity will be driven by budget estimates and whether they can follow the reduction to the federal taxable income base while still balancing their budgets.
Disallowed transportation fringe benefit rules proposed
The IRS issued proposed regulations implementing changes to Sec. 274 that disallow a deduction for the expense of any Sec. 132(f) qualified transportation fringe provided to an employee, effective for amounts paid or incurred after Dec. 31, 2017.
Private equity and F reorganizations involving S corporations
The M&A market is poised to regain its pre-COVID-19 activity levels as many business owners seek to exit closely held businesses or explore alternatives. One popular transaction that could emerge is Sec. 368(a)(1)(F) reorganizations F reorganizations) of S corporations.
Treasury issues proposed regulations on Sec. 47 rehab credit
the IRS published proposed regulations regarding the Sec. 47 rehabilitation tax credit, including rules to coordinate the new five-year period over which the credit may be claimed with other special rules for investment credit property.
IRS permits leave-based donation programs during pandemic
The IRS announced that employers may make donations this year to charitable organizations that provide relief to COVID-19 pandemic victims in exchange for personal leave that their employees forgo.
Regulation package defines NOL rules for consolidated groups
The IRS issued proposed and temporary regulations explaining how consolidated groups should apply the changes to the net operating loss rules enacted by the CARES Act.
TAX PRACTICE MANAGEMENT
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