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.
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TOPICS
C Corporation Income Taxation
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.
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.
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.
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.
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.
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.
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.
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.
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 .
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.
Traversing Sec. 163(j) aggregation for affiliated service groups
This discussion provides a high-level overview of the affiliated service group rules.
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.
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.
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.
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.
Worldwide combined reporting: An underutilized opportunity
This discussion focuses on how state worldwide reporting works and what taxpayers should consider in determining whether to elect it or avoid it.
Limiting business interest expense
Under new Sec. 163(j), business interest expense deductions are limited, and a business interest expense that is disallowed in the current year is
carried forward to the succeeding tax year.
Rethinking NOL waivers by a consolidated group
Now that NOL carryforwards are unlimited for tax years beginning after Dec. 31, 2017, practitioners
should be rethinking the use of the waiver of NOL carryforwards under Regs. Sec. 1.1502-32(b)(4) in acquisitions of a company with NOLs by a member of a consolidated group.
Impact of S corp. shareholder agreements in M&A transactions
Shareholders and their advisers should be prepared to verify the validity of the S election when the decision is made to begin marketing the company
for sale.
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.
