Selling off and replacing assets could result in a possible taxable gain. A common business practice for avoiding such a gain is to engage in a Sec. 1031 exchange.
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TOPICS
C Corporation Income Taxation
Should Some Frequent Flier Miles Be Exempt From Excise Tax?
The IRS on Thursday asked for feedback on whether frequent flier miles that are redeemed for anything other than taxable air transportation should be exempt from the Sec. 4261 excise tax.
Expired Tax Provisions: No Relief in Sight?
It’s a good time to review which provisions might get a last minute reprieve and see what legislation is pending in Congress.
Tax Planning Businesses Can Do Before Year End
Here are some suggestions to help business clients reduce 2015 taxes by accelerating deductions into this year and delaying income until next year.
IRS Expands Range of D Reorganizations, Highlights Importance of the Form of a Taxpayer’s Transaction
IRS rules expand the range of transactions that qualify as type D acquisitive asset reorganizations and signaled a greater willingness to accept a taxpayer’s chosen form of reorganization transaction.
Capitalization Not Required for Payment to Terminate Management Agreement Prior to IPO
In a Letter Ruling, the IRS concluded that a payment made to terminate a management services agreement did not create an intangible asset or facilitate a transaction.
Final Rules Govern F Reorganizations
The final rules apply a concept called a potential F reorganization, allowing the many steps of a corporate reorganization to be examined together to see if the transaction qualifies to be an F reorganization.
Rules Target Abuse of “Legging Out” of Foreign Currency Hedges
Final regulations issued on Friday clarify the tax treatment of certain terminations of qualified hedging transactions under Sec. 988.
Statute of Limitation for Tax Carryovers
It is not unusual for a taxpayer to make an error on a return that results in a misstatement of a net operating loss or a credit that is then carried forward. These mistakes might not be noticed until after the statute of limitation is closed.
IRS Prohibits Corporations From Circumventing Gain on Appreciated Property Using Partnerships
The IRS issued more regulations that take aim at transactions that attempt to avoid the repeal of the General Utilities doctrine.
Dealing With ISOs and Disqualifying Dispositions in Reorganizations
A recent Chief Counsel advice provides guidance on disqualifying dispositions of incentive stock options in reorganizations.
Deducting Expenses for Sporting Events Under an Accountable Plan
There are some unique rules for sporting and other live entertainment events under accountable plans.
Benefits and Burdens Would No Longer Determine Sec. 199 Deduction
The IRS has proposed removing the benefits-and-burdens-of-ownership rule for determining which party to a contract manufacturing agreement should get the Sec. 199 domestic production activities deduction.
Benefits and Burdens Would No Longer Determine Sec. 199 Deduction
The IRS has proposed removing the benefits-and-burdens-of-ownership rule for determining which party to a contract manufacturing agreement should get the Sec. 199 domestic production activities deduction.
Regulations Determine Allocation of Wages for Domestic Production Activities Deduction
The new rules govern the Sec. 199 deduction when two taxpayers employ the same employees.
Deemed Dividends on Convertible Debt Under Sec. 305(c)
Over the past decade or so, several public companies have issued convertible debt instruments that provide for a conversion rate adjustment so that a conversion rate is changed if a distribution is made on corporate stock.
Final Rules Define Substantial Business Activities Under Sec. 7874
The IRS issued final regulations to determine when an expanded affiliated group will be considered to have substantial business activities in a foreign country, which could allow a foreign corporation to escape application of the inversion rules.
Attacking Transactions to Evade General Utilities Repeal
Temporary regulations prevent corporations from avoiding tax through the use of partnerships.
Tax Court Invalidates Stock-Based Compensation Rule in Cost-Sharing Agreements
The Tax Court held that Regs. Sec. 1.482-7(d)(2), requiring entities to share stock-based compensation costs under qualified cost-sharing agreements, failed to meet the reasoned decision-making standard and was invalid.
“Substantially Complete” Buildings Eligible for GO Zone Depreciation
In Stine, LLC, No. 2:13-cv-03224 (W.D. La. 1/27/15), a retailer’s store buildings were considered “placed in service” for federal tax depreciation purposes when they were “substantially complete” rather than when they subsequently were “open for business” resulting in the taxpayer’s being able to take an accelerated depreciation deduction for the buildings. This decision highlights the importance of properly identifying an asset’s placed-in-service date.
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.
