C Corporation Income Taxation

TOPICS

February 1, 2020

A road map for tax function automation

This article discusses methods and strategies for how a corporate tax department can move forward in its quest for tax function automation.

February 1, 2020

Recent nonstatutory state reactions to Wayfair

Several states have begun extending the economic nexus standard approved in Wayfair beyond sales tax, adopting economic nexus provisions for
corporate income taxes.

January 1, 2020

Five areas of focus as companies work to implement the TCJA

This article discusses the areas that may continue to
pose TCJA implementation challenges for companies.

January 1, 2020

Tax Court shoots down finder’s fee deduction

A company acquired by another company cannot take a deduction for a fee from the acquisition transaction that it paid on behalf of the acquiring company.

January 1, 2020

Prop. regs. address eliminating LIBOR, other interbank-offered rates

To facilitate the transition away from IBORs and minimize the resulting market disruption, the IRS
issued the proposed regulations with an aim of reducing associated tax uncertainty and taxpayer burden.

January 1, 2020

The business meal expense deduction after the TCJA

This article explores the competing perspectives and discusses the IRS’s interim guidance on the deductibility of business meals.

January 1, 2020

Prop. regs. would eliminate Sec. 338 safe harbor, modify calculations

This discussion provides an overview of the current Sec. 382 regime, and then discusses the significant
changes in the proposed regulations and their implications.

December 17, 2019

Proposed regs. would govern Sec. 162(m) executive compensation limits

The IRS issued proposed regulations on the Sec. 162(m) $1 million limit on executive compensation paid by certain publicly held corporations.

December 1, 2019

Industrial hemp: A growing industry

The end to hemp prohibition opens new industrial business opportunities for clients, making it important that CPAs have a working knowledge of industrial hemp.

December 1, 2019

R&D tax credit: Don’t leave money on the table

Many taxpayers do not realize that the R&D tax credit is available to businesses of all sizes in many lines of business, not just major corporations conducting tests in research laboratories.

December 1, 2019

Proposed rules would govern built-in gains and losses

The IRS issued proposed regulations that provide a safe harbor for corporations to calculate built-in gains and losses after an ownership change.

November 1, 2019

Stock redemption: Capital gain or ordinary income?

Sec. 302 affords a shareholder the advantage of sale or exchange (capital gain transaction) treatment on redeemed stock but only if the
redemption meets one of several tests.

November 1, 2019

New IRS compliance campaigns

LB&I recently announced it was adding six new
compliance campaigns to its list of areas on which to focus its examinations.

October 1, 2019

Demystifying the new international E&P rules

This discussion provides a summary of some of the basic previously taxed earnings and profits ordering rules likely to apply to distributions made by controlled foreign corporations .

October 1, 2019

US MNCs facing implications of economic (vs. physical) nexus

This item summarizes the complexities of a digitalized economy for MNCs and considers the
multifaceted implications to U.S. MNCs with respect to financial statements and tax reporting.

October 1, 2019

Traversing Sec. 163(j) aggregation for affiliated service groups

This discussion provides a high-level overview of the affiliated service group rules.

October 1, 2019

IRS releases guidance on treatment of transaction costs

The IRS’s Large Business and International
Division released “Examining a Transaction
Costs Issue” regarding the treatment of transaction costs incurred in certain business transactions.

September 12, 2019

Corporations have short period to apply for IRS CAP program

The IRS announced that it is opening its Compliance Assurance Process (CAP) program to new applicants for the first time in years, but applications must be made between Sept. 16 and Oct. 31.

September 10, 2019

Built-in gains and losses subject of new proposed regs.

The IRS issued proposed regulations that provide a safe harbor for corporations to calculate built-in gains and losses after an ownership change.

September 1, 2019

Application of new life insurance reportable policy sale rules to M&A transactions

Recently issued proposed regulations on the transfer of life insurance contracts create significant uncertainty regarding their application to tax-free asset acquisitions.