The IRS recently promulgated final regulations that prohibit a taxpayer from increasing research credit carryforwards from closed years by electing the ASC method.
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TOPICS
C Corporation Income Taxation
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.
Applicability of Sec. 1031 in Exchange of Agreements
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.
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.
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.
