The Tax Court discussed the application of the “boot” rules under Sec. 356 in a tax-free reorganization.
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TOPICS
C Corporation Income Taxation
Notice 2015-79: New Anti-Inversion Guidance
IRS inversion guidance introduces new restrictions on corporate inversions and post-inversion restructuring transactions.
Earnings Stripping: Effective Tax Strategy to Repatriate Earnings in a Global Economy
Earnings-stripping strategies can be an effective way to repatriate earnings at little or
no tax cost; however, taxpayers must be aware of the rules under Sec. 163(j).
Personal Goodwill and the Net Investment Income Tax
This article discusses when the sale
of goodwill related to a C corporation is the sale of a shareholder’s personal goodwill
and the reasons the gain from the sale of personal goodwill should not be subject to
the net investment income tax.
IRS’s Inversion Rules Include Earnings-Stripping Provisions
These new rules aim to curtail an inverted company’s ability to access foreign subsidiaries’ earnings without paying U.S. tax.
Recent Guidance Affecting Research Credit Carryforwards From Closed Years
The IRS recently promulgated final regulations that prohibit a taxpayer from increasing research credit carryforwards from closed years by electing the ASC method.
Loss Importation Rules Limit Built-In Losses
The Internal Revenue Service finalized rules that limit the ability of a taxpayer to transfer loss property to a corporation.
Regulations Finalize Coordination Rules for Outbound Reorganizations
The IRS issued regulations that eliminate an exception to the coordination rule between asset transfers and indirect stock transfers for certain outbound asset reorganizations and modify an exception to the coordination rule.
“Cadillac” Health Plan Excise Tax Delayed Until 2020
The so-called Cadillac plan excise tax is now scheduled to take effect in 2020.
President’s Budget Proposes Many Tax Changes
In addition to a proposed spending blueprint for the government, President Barack Obama’s proposed FY 2017 federal budget contains a wide variety of tax law changes that would affect individuals and businesses.
Practical Strategies for Using Sampling for the Research Tax Credit
This item discusses efficient strategies for a tax department to consider when planning a statistical sample to estimate qualified research
expenditures.
Final F Reorganization Regs. Might Make Treatment Available for Reverse Mergers
A company that uses a reverse merger to go public generally would like to structure the merger as a tax-free reorganization.
Sec. 163(I)’s “Substantial Certainty” Test and Related-Party Convertible Debt
This item summarizes the current law and discusses the facts and conclusion in Letter Ruling 201517003.
New Rules Aimed at Further Curtailing Inversions
The IRS announced new rules rules designed to curtail the ability of an inverted company to access foreign subsidiaries’ earnings without paying U.S. tax.
Recognizing and Measuring Tax Benefits From Uncertain Tax Positions
Once all uncertain tax positions have been identified, FASB Accounting Standards creates a two-step process to recognize and measure the tax benefits arising from those positions.
Tax Extender Legislation Introduced in Congress
The Consolidated Appropriations Act introduced in Congress on Wednesday would extend a large number of expired tax provisions.
IRS Finalizes Potential F Reorganization Rules
Corporations that meet six requirements will be able to effectuate F reorganizations tax-free in some cases.
New Corporate Anti-Inversion Rules Issued
The IRS announced additional rules designed to curtail the ability of an inverted company to access foreign subsidiaries’ earnings without paying U.S. tax.
Acquisition of Partnership Interest Constitutes an Expansion of Distributing Corporation’s Business
The IRS ruled that a distributing corporation’s
acquisition of an interest in a partnership was not an acquisition of a new or different business.
Proposed Regulations Would Provide Guidance for Allocation and Absorption of Losses on a Consolidated Return
Proposed regulations address an issue when there is a consolidated net operating loss.
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.
