C Corporation Income Taxation

TOPICS

June 30, 2025

Federal excise tax traps for the unwary

Editor: Mary Van Leuven, J.D., LL.M. The U.S. government imposes federal excise taxes that can affect a surprising variety of companies. These taxes include the foreign insurance excise tax, the Patient–Centered Outcomes Research Institute (PCORI) fee, and the relatively new stock repurchase excise tax. Compliance with these taxes can be

June 30, 2025

Global expansion of e-invoicing and digital reporting obligations for nonresidents

Countries are expanding e-invoicing and digital reporting obligations to nonresidents to increase value-added-tax compliance.

June 30, 2025

Strategic trade management in 2025: Navigating and mitigating tariffs

As tariffs continue to affect costs, U.S. importers can employ these strategies to minimize their duty exposure.

June 30, 2025

CHIPS Act final regs. offer many taxpayer-friendly provisions

Congress incentivized domestic manufacturing of semiconductors and semiconductor manufacturing equipment as part of the Creating Helpful Incentives to Produce Semiconductors (CHIPS) Act of 2022.

June 16, 2025

AICPA makes Priority Guidance Plan recommendations to IRS

In addition to its 183 recommendations for the IRS plan, the AICPA encouraged the agency to continue to pursue tax simplification.

June 11, 2025

Appeals court leaves tariffs in place, seeks expedited argument schedule

A federal appeals court extended its stay of a nationwide injunction on tariffs imposed by a trade court and proposed a schedule that would include oral arguments on July 31 in the challenge to the president’s authority.

June 11, 2025

The proposed PTEP rules: Tax basis considerations under Sec. 961

Proposed regulations for previously taxed earning and profits of foreign corporations address a range of considerations for shareholder basis adjustments.

June 10, 2025

Using transfer pricing to blunt the effects of tariffs

Understanding the interrelationship of transfer pricing and tariffs is key to mitigating the effect of those levies on earnings.

June 3, 2025

Disregarded-payment-loss rules: How multinationals should prepare

New final regulations pose significant implications for possible income inclusions by U.S. corporations with foreign disregarded entities.

June 3, 2025

Simplified method to determine corporate AMT applicable status issued

A notice issued by the IRS with interim guidance for the application of the corporate alternative minimum tax offers an optional simplified method for determining applicable corporation status under Sec. 59(k).

May 31, 2025

Navigating the complex interplay between Secs. 108(e)(6) and 367(c)(2)

A common method of resolving intercompany debt can entail ambiguity when a foreign subsidiary is involved, due to a dearth of regulatory guidance.

May 31, 2025

Tax planning for health care management services organizations

Management service organizations, common in the health care industry, can provide certain tax advantages.

May 31, 2025

Apportioning tax benefits among members of a controlled group

Maintaining an apportionment plan among component members can help ensure optimal tax results.

May 28, 2025

Elections under the new Sec. 987 final regs.

Businesses with foreign branches receive new guidance on adjusting for currency exchange gain or loss.

May 21, 2025

Placing in service the benefits of the Inflation Reduction Act

Determining when energy property is eligible for a tax credit or deduction hinges on when it is first placed in service, which can be controversial.

April 30, 2025

Legacy clean-energy credits evolve into tech-neutral credits

The transition beginning in 2025 entails certain new requirements but also opportunities.

April 30, 2025

Combining debtor and creditor positions: COD income considerations

Cancellation-of-debt income arises in a variety of merger-and-acquisition contexts, often with unclear tax treatment.

April 30, 2025

Treatment of digital assets transferred to employees

Sec. 83 governs the tax treatment of digital assets that employees receive in connection with their performance of services.

April 30, 2025

Tax implications in the automotive industry: The core of remanufacturing

Remanufactured “cores,” or used vehicle parts, are essential to the automotive industry but present distinct special tax and accounting considerations.

April 29, 2025

AICPA comments on proposed regs. on new transfer-pricing method

The comments are in response to Notice 2025-04, which announced plans for the simplified and streamlined approach as a new transfer-pricing method under Sec. 482 regulations for pricing of baseline marketing and distribution activities.