The organization highlighted top technical issues across 10 areas and urged the IRS to prioritize tax simplification.
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TOPICS
C Corporation Income Taxation
Identifying the final C corporation and initial S corporation tax years
Rules determine allowable tax years after a C corporation elects S status.
Access to energy: A ‘new’ intangible asset?
Some leases and other contracts for priority access to electricity needed for new technologies may require 15-year amortization under Sec. 197.
Demystifying reattribution: Disregarded payments and the FTC limitation
Adjustments under the disregarded-payment and foreign tax credit rules are often overlooked. This practical framework includes a step-by-step guide and example.
Gray areas of Sec. 1202 warrant regulatory guidance
While recent legislation has further boosted the benefits of the qualified small business stock gain exclusion, official guidance is needed to clarify ambiguities.
Frequently encountered controversy issues in M&A transactions
Procedural issues involving entity change in mergers and acquisitions can be managed by attentiveness and, in many cases, relief provisions.
Application of grandfathering rules under Sec. 162(m) to severance plan payments
The rules hinge on whether a corporation remains obligated since Nov. 2, 2017, to pay an amount under a written binding contract that has not been materially modified after that date.
Dissolving business taxpayers: Selected procedural implications
Critical issues include marking returns as final, determining due dates for final returns, filing Form 966, closing IRS accounts, and handling audits of dissolved entities.
Deductibility of transaction costs incurred by an indirectly acquired entity
Although the IRS has provided guidance on success-based fees, determining which parties are the acquirer and target can be difficult when multiple entities are involved in an M&A.
IRS issues guidance on treaty application to reverse foreign hybrids
The IRS provides guidance on whether these entities qualify under a U.S. federal income tax treaty for relief from the branch profits tax.
Practical tax issues related to qualified reopenings
Treating multiple debt instruments as a single issuance under Sec. 1275 and its regulations can have tax advantages but is often overlooked.
Partner redemptions from ‘dry’ partnerships
A partnership whose sole asset is all the stock of a corporation offers opportunities but with potential pitfalls.
Navigating safe-harbor rules for solar and wind Sec. 48E facilities
Early termination of the clean energy investment credits for solar and wind under the law known as the One Big Beautiful Bill Act means projects must start construction by July 4, 2026.
Businesses urge Treasury to destroy BOI data and finalize exemption
Just over 100 business associations asked Treasury Secretary Scott Bessent to purge previously submitted beneficial ownership information records and quickly finalize a rule exempting U.S. companies from BOI reporting.
IRS generally eliminates 5% safe harbor for determining beginning of construction for wind and solar projects
A notice limits methods of meeting a key deadline for project eligibility for two clean energy credits, which recent legislation terminated after 2027.
Deducting corporate charitable contributions
Some key limitations and
requirements differ from those
with respect to individuals.
SECURE 2.0 amendment deadline extended for IRAs, other retirement plans
The IRS extended the deadline for SECURE 2.0 related amendments to IRAs, SEPs, and SIMPLE IRAs to Dec. 31, 2027, saying that additional time is needed to complete model language.
Revisiting Sec. 1202: Strategic planning after the 2025 OBBBA expansion
This powerful vehicle for excluding gain on qualified small business stock gains even more traction under new legislation.
Practical tax advice for businesses as a result of the OBBBA
H.R. 1, P.L. 119-21, the law commonly known as the One Big Beautiful Bill Act (OBBBA), contains provisions of special interest to business taxpayers. This article summarizes some of them and offers tax planning tips.
IRS updates FAQs on business interest limitation, premium tax credit
The updates reflect changes made in H.R. 1, P.L. 119–21, commonly known as the One Big Beautiful Bill Act.
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.
