The IRS announced that it is reviewing its approach to the active trade or business requirement that must be met for a five-year period for a business to qualify for a tax-free spinoff under Sec. 355 and, as a result, is suspending two revenue rulings, Rev. Ruls. 57-464 and 57-492, in which it previously ruled on the topic.
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TOPICS
C Corporation Income Taxation
Corporate transactions’ effect on retirement plans
This article discusses several key factors that CPAs and benefit plan advisers should consider to help successfully integrate plans during a merger or acquisition.
Opportunities beckon in new qualified opportunity zones
With their prospects for deferral or even exclusion of gains from certain investments in them, the newly created qualified opportunity zones offer an intriguing tax planning option for investors and a potential boon for distressed communities.
Potential pitfalls of charitable contribution substantiation and reporting
Failure to properly complete all required fields on Form 8283, including the donor’s cost or other basis, could jeopardize the entire deduction with respect to the donated property.
New business interest expense rules issued in proposed form
The IRS issued proposed regulations on the business interest expense limitation in Sec. 163(j), which was amended by the law known as the Tax Cuts and Jobs Act.
Commitment fees related to revolving credit agreement
The IRS released advice that concluded that an accrual-based taxpayer was entitled to deduct quarterly commitment fees paid related to its
revolving credit agreement.
Unintended consequences: How a drafting glitch turned Sec. 958 upside down
This item provides an overview of the Sec. 958 constructive ownership rules, explores the “glitch” and its consequences, and discusses planning options to mitigate the negative effects.
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.
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.
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.
Proposed bonus depreciation regs. provide answers, create new questions
The proposed regulations clarify the elections available to all taxpayers regarding bonus depreciation.
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.
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.
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.
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.
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.
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.
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.
IRS releases guidance on new paid family and medical leave tax credit
Sec. 45S requires that an eligible employer for purposes of claiming the family and medical leave credit must have in place a written policy meeting certain requirements.
Recognizing when the IRS can reallocate income
The IRS can take advantage of several rules to ensure related-party transactions do not result in tax evasion or an improper reflection on income.
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.
