This article offers guidance on helping clients take advantage selling personal goodwill as a tax strategy.
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TOPICS
C Corporation Income Taxation
Qualifying as a Small Business Corporation for AMT Purposes
A corporation qualifying for small business corporation status avoids both the administrative burden and the potential additional tax liability of the AMT.
Automobile Depreciation Limits Issued for 2014
The IRS issued the 2014 inflation adjustments to the depreciation limitations and lease inclusion amounts for certain automobiles under Sec. 280F.
Automatic Recognition of Consolidated Return Filing Status Permitted
An affiliated group of corporations that did not file a consolidated return for the immediately preceding tax year may file a consolidated return in lieu of separate returns for the tax year under certain conditions.
Cancellation of Debt Income for Debtor Subsidiary Corporations
This item addresses the U.S. corporate income tax effects of cancellation of debt (COD) income; the contribution-to-capital exception to COD income; partial cancellation of COD income; the impact of insolvency; and, finally, some COD income issues to consider in the international corporate context.
Bringing Clarity to Fuel Excise Taxes and Credits
The federal excise taxes, tax credits, and exemptions for various types of fuel constitute a confusing area of the tax law. This item is intended to clear up much of the confusion faced by taxpayers and advisers alike when attempting to claim these tax credits.
Structuring Minority Interest Acquisitions With a Step-Up in Basis: Sec. 1239 and Beyond
A recent court decision is a reminder of the related-party traps and the importance of properly structuring a minority investment.
Foreign Corporations: Procedures and Pitfalls in Adopting and Changing Methods of Accounting for Purposes of Determining E&P
This item provides a high-level discussion of the general timing for certain foreign corporations’ adoption of methods of accounting for purposes of determining E&P, the procedural rules regarding how such foreign corporations change their method of accounting, and the importance of understanding when and how a method is adopted in light of the increased limitations such foreign corporations may face in changing methods.
Major Developments in Cost Segregation
This article discusses the rules that must be followed to use the principle of cost segregation in any form.
Final Rules Issued on Employment Tax Responsibilities of Designated Payer Agents
Final regulations contain rules on the liability for employment taxes when an employer designates an agent under a “service agreement” to pay its employees and to satisfy its employment tax obligations instead of following normal IRS procedures to designate an agent.
New Procedure Permits Automatic Recognition of Consolidated Return Filing Status
The IRS announced that it will permit an affiliated group of corporations that did not file the required Form 1122 for all of its subsidiaries to be treated as if its subsidiaries had filed Form 1122.
Final Regs. Govern Sales-Based Royalties and Vendor Allowances
The IRS issued final regulations on sales-based royalties and vendor allowance rules.
Earnout Restriction Causes Substantial Risk of Forfeiture
The Tax Court held that sections of a restricted stock agreement and an employment agreement read together constituted an earnout restriction that might create a substantial risk of forfeiture for stock transferred to an employee.
2014 Car, Truck Depreciation Limits Issued
The IRS issued the 2014 inflation adjustments to the depreciation limitations and lease inclusion amounts for certain automobiles under Sec. 280F.
Cost Basis Denied Due to Failure to Meet the All-Events Test
The Court of Federal Claims denied approximately $1.6 billion in cost basis related to decommissioning liabilities assumed in connection with the purchase of three nuclear power plants.
Cloud Computing and the Credit for Increasing Research Activities
This item focuses on how a taxpayer’s rental expenses for cloud computing for purposes of research and development of new products and solutions should be treated under the Sec. 41 research tax credit.
Solving a Problem With Sec. 338 Purchase-Price Allocations
This item illustrates the surprising problem that can arise Sec. 338 purchase-price allocations and suggests a solution.
Sec. 382 Final Regs. for Small Shareholders
This item provides a brief background on the regulations under Sec. 382 and then discusses the two substantive changes and some planning opportunities.
Sec. 199 Contract Manufacturing Guidance May Encourage Taxpayers to Agree on Benefits and Burdens
Directives issued by the IRS Large Business & International Division describe circumstances in which the IRS will not challenge the taxpayer’s position that it has the benefits and burdens of ownership for purposes of the Sec. 199 deduction.
Hook Stock and Sec. 355: Did a Distribution Occur?
By invoking an exception to the requirement that a distributing corporation must distribute “all of the stock and securities in the controlled corporation,” the IRS implicitly held that a distribution on hook stock should not be respected.
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.
