C Corporation Income Taxation

TOPICS

February 1, 2019

Missing links: Tax reform’s impact on the value chain

In a changing landscape, U.S. C corporation multinationals should consider reevaluating their value chain.

February 1, 2019

More positive news for taxpayers with pilot model supply expenses

Recent events should give taxpayers greater confidence to include pilot model expenses as Sec. 74 expenses and R&D supply costs.

February 1, 2019

First round of opportunity zone guidance offers flexibility for investors, but questions remain

Taxpayers should carefully review the proposed regulations for relevant limitations and be mindful of how future guidance may affect their investments.

February 1, 2019

Proposed bonus depreciation regs. provide answers, create new questions

The proposed regulations clarify the elections available to all taxpayers regarding bonus depreciation.

February 1, 2019

Sec. 162(m) grandfather rule can apply to more than just performance-based compensation

The Sec. 162(m) grandfather rule provides multiple opportunities outside of the exemption for performance-based compensation.

February 1, 2019

Managing corporate state net operating losses

This article offers guidance on maximizing the use of corporate state NOLs, recording deferred
tax assets and valuation allowances for them, and incorporating their value in the pricing of M&A transactions.

February 1, 2019

IRS says no to dividends-received deduction related to ETF shares

The IRS concluded that a derivative that referenced a stock index was “substantially similar or related
property” to the stock of an exchange-traded fund that held the components of the index.

February 1, 2019

IRS issues chief counsel advice on success-based fees

The IRS concluded that a taxpayer was required to capitalize 100% of an investment banking fee because it failed to satisfy the documentation requirement for success-based fees under Regs. Sec. 1.263(a)-5.

January 10, 2019

The TCJA’s effect on future R&D tax credit planning

This article discusses the modifications made to Sec. 174 and Sec. 41, which will affect taxpayers’ R&D tax credit claims for tax years after Dec. 31, 2021.

January 1, 2019

Proposed GILTI regs. provide useful guidance on certain consolidated return issues

The proposed regulations effectively treat a consolidated group as a single entity for purposes of determining the sharing of tested loss.

January 1, 2019

Certain moving expenses incurred in 2017 not subject to withholding and employment tax in 2018

Employer reimbursements made in 2018 of qualified moving expenses incurred prior to 2018 in connection with a move that occurred prior to Jan. 1, 2018, may be excluded from employees’ wages and gross income despite the suspension of the exclusion for tax years 2018 through 2025.

January 1, 2019