Final regulations were issued for determining when an expanded affiliated group will be considered to have substantial business activities in a foreign country, which allows a foreign corporation to escape application of the inversion rules.
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TOPICS
C Corporation Income Taxation
IRS Applies Option Rule to Find Covered Transaction for 50% or Less Stock Acquisition
Some taxpayers that incur costs for taxable stock acquisitions after which they own less than 50% of a corporation may qualify for an exception.
Evolving Trends in Captive Insurance
Recent tax developments relating to captive insurance companies present potential new opportunities for some captive arrangements while raising caution about others. This item highlights current, practical considerations regarding qualification of a captive as an insurance company for federal income tax purposes.
Former Shareholders Held Liable for Corporate Tax Debt
The Tax Court held that the four former shareholders of a corporation were liable as transferees for a portion of the tax debts of the corporation arising from a land sale that occurred before they sold their stock in the corporation to a third party.
IRS Issues Final Rules on Performance-Based Compensation
IRS finalized regulations regarding the exception under Sec. 162(m)(4)(c) to the $1 million deduction limitation for compensation paid by publicly held corporations to covered employees.
Rulings Illustrate Transactions That Qualify as D Reorganizations
The IRS issued two rulings on transactions that qualify as D reorganizations and revoked Rev. Rul. 78-130.
The Principal Tax-Avoidance Purpose: A Poison Pill for Inversions?
This item considers possible challenges by the IRS using the principal tax-avoidance purpose under Sec. 7874.
Support for Corporate Structure Under State Corporate Practice of Medicine Rules
The IRS concluded that two professional corporations could file a consolidated return with another corporation, even though licensed professionals, not one of the members of the consolidated return group, were the actual legal owners of these PCs’ stock, as required by state law.
Tax Considerations for Cancellation-of-Debt Income
This item provides an overview of the U.S. income tax implications of cancellation-of-debt income that results from bankruptcy or insolvency, with a focus on the differences in the tax treatment for C corporations, S corporations, and partnerships.
Considering Alternatives to Liquidation
Shareholders might want to liquidate a corporation for several reasons, but in some cases, a plan of action other than liquidation might better meet their objectives.
Cost-Segregation Studies and the Impact of the Tangible Property Regulations
This item highlights several important aspects of the final tangible property regulations and related transition guidance that may affect cost-segregation studies and resulting changes in accounting methods.
GAAs Are a Valuable Planning Option for Tangible Property Depreciation
General asset accounts provide a valuable simplification tool for tracking tangible assets and present some tax planning opportunities.
Incorporating a Partnership and Selling to an ESOP in a Tax-Free Transaction
This item explores the main issues a partnership should consider from a restructuring perspective when considering ESOP ownership transactions.
Rules Governing Internal-Use Software Are Proposed
The IRS issued long-awaited proposed regulations on what type of internal-use software qualifies for the Sec. 41 research credit. Although the new rules are proposed, not final, the IRS says it will not challenge taxpayers’ return positions that apply these rules currently.
Qualified Performance-Based Compensation Rules Are Finalized
The IRS issued final regulations regarding the exception under Sec. 162(m)(4)(c) to the $1 million deduction limitation for compensation paid by publicly held corporations to covered employees.
The Importance of Being Flexible: Choice-of-Entity Considerations
This item presents an overview of some of the tax points that should be kept in mind when choosing an entity.
Proposed Regulations Would Require Gain or Loss Recognition on Certain Installment Obligation Transfers
The IRS issued proposed regulations that would require transferors that transfer installment obligations for equity interests in corporations or partnerships in nonrecognition transactions in satisfaction of those obligations to recognize gain or loss.
Employers Have More Time to Claim Work Opportunity Tax Credit
The IRS announced that it was extending the time employers that want to claim the work opportunity tax credit have to file Form 8850 for 2014 hires.
Final Guidance Related to Tangible Property Regulations Provides Time-Limited Opportunities
IRS released guidance related to the tangible property regulations regarding depreciation and dispositions.
Sampling to Efficiently Implement the New Tangible Property Regulations: The Clock Is Ticking
New tangible property regulations apply to all current and certain prior-year tangible assets, creating compliance efforts and opportunities for immediate and long-term tax savings.
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.
