New final regulations pose significant implications for possible income inclusions by U.S. corporations with foreign disregarded entities.
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TOPICS
C Corporation Income Taxation
Simplified method to determine corporate AMT applicable status issued
A notice issued by the IRS with interim guidance for the application of the corporate alternative minimum tax offers an optional simplified method for determining applicable corporation status under Sec. 59(k).
Navigating the complex interplay between Secs. 108(e)(6) and 367(c)(2)
A common method of resolving intercompany debt can entail ambiguity when a foreign subsidiary is involved, due to a dearth of regulatory guidance.
Tax planning for health care management services organizations
Management service organizations, common in the health care industry, can provide certain tax advantages.
Apportioning tax benefits among members of a controlled group
Maintaining an apportionment plan among component members can help ensure optimal tax results.
Elections under the new Sec. 987 final regs.
Businesses with foreign branches receive new guidance on adjusting for currency exchange gain or loss.
Placing in service the benefits of the Inflation Reduction Act
Determining when energy property is eligible for a tax credit or deduction hinges on when it is first placed in service, which can be controversial.
Legacy clean-energy credits evolve into tech-neutral credits
The transition beginning in 2025 entails certain new requirements but also opportunities.
Combining debtor and creditor positions: COD income considerations
Cancellation-of-debt income arises in a variety of merger-and-acquisition contexts, often with unclear tax treatment.
Treatment of digital assets transferred to employees
Sec. 83 governs the tax treatment of digital assets that employees receive in connection with their performance of services.
Tax implications in the automotive industry: The core of remanufacturing
Remanufactured “cores,” or used vehicle parts, are essential to the automotive industry but present distinct special tax and accounting considerations.
AICPA comments on proposed regs. on new transfer-pricing method
The comments are in response to Notice 2025-04, which announced plans for the simplified and streamlined approach as a new transfer-pricing method under Sec. 482 regulations for pricing of baseline marketing and distribution activities.
The close of deferral: Planning for the QOZ end game
Many investors in qualified opportunity zones face a large upcoming tax hit when their QOZ deferral ends. They should consider harvesting stock market losses in advance of it.
Sec. 280G and the evolving executive compensation landscape
The affiliated-group rules and other complications can require care in determining application of this excise tax on compensation paid in connection with a change of corporate control.
The funding rule under Sec. 4501(d) prop. regs.
Proposed regulations under Sec. 4501 apply the stock repurchase excise tax to a parent corporation that “funds by any means” a stock repurchase. But the proposed regulations lack clarity on the phrase’s interpretation.
IRS increases scrutiny of business aircraft use
Businesses that own, lease, or charter aircraft should prepare for increased IRS scrutiny by closely reviewing their compliance with applicable tax provisions.
FTR notification requirement for taxpayers under LB&I examination
A foreign tax redetermination may require taxpayers under Large Business and International Division examination to notify the IRS, which will redetermine the U.S. tax owed.
A closer look at the costs of borrowing
Comparison of the accounting and tax treatment of interest expense may reveal crucial differences and lead to best practices for managing it.
The research credit: Business-component requirement
The Fifth Circuit’s decision in Grigsby, 86 F.4th 602 (5th Cir. 2023), emphasizes the need for taxpayers to clearly define business components when preparing and documenting their Sec. 41 credit.
How Trump’s opposition to global tax deal may affect businesses
The Trump administration has rejected the OECD’s initiative to reform the taxation of multinational enterprises. Learn more about the executive action in this Q&A with an international tax expert.
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.
