The final and reproposed tangible property regulations will significantly affect the oil and gas industry. Specifically, the unit-of-property determination has different implications for oil and gas companies, depending on which segment the companies operate in.
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TOPICS
C Corporation Income Taxation
“Beginning of Construction” for the Renewable Electricity Production and Energy Investment Tax Credits
The IRS clarified Notice 2013-29 defining the beginning of construction for purposes of the Sec. 45 renewable electricity production tax credit and the Sec. 48 energy investment tax credit.
Proposed Regs. Clarify Research Expenditure Eligibility Under Sec. 174
The IRS in September issued proposed regulations clarifying the application of Sec. 174 to the costs to create “pilot models” or prototypes. The proposed rules state that the reason a taxpayer creates a prototype or other product, and not its subsequent sale or use, determines whether it qualifies under Sec. 174.
IRS Finalizes Regs. Addressing Limitations on Transfers of Built-In Losses
The IRS issued final regulations under Sec. 362(e)(2) that provide guidance on the determination of the bases of assets (including stock) transferred in certain nonrecognition transactions to which Sec. 362(e)(2) limitations on built-in losses apply.
Sec. 631(b) and the Taxation of Standing Timber Sales
Under Sec. 631(b), gains or losses from the sale of standing timber are considered gains and/or losses from the sale of business use property.
Heightened Emphasis on Worker Classification
Worker classification has been a major concern for many years. While it is clear that government agencies recognize that worker misclassification is a significant problem, how to classify workers remains unclear.
IRS Issues Repair/Tangible Property Regulations
The IRS issued long-awaited final and proposed regulations regarding the treatment of expenditures incurred in acquiring, producing, or improving tangible assets.
CFC’s Software Leasing Income Determined to Be Foreign Personal Holding Company Income
The IRS addressed whether rental income from software leasing to third parties outside the country of a controlled foreign corporation is foreign personal holding company income.
Deferral of Income From Sales of Gift Cards
The IRS issued Rev. Proc. 2013-29, which allows taxpayers to defer income from the sale of gift cards or gift certificates redeemable by an unrelated entity until the cards or certificates are redeemed for goods and services by that entity.
Final Regs. Issued on Deferral of COD Income and OID Deductions
The IRS issued final regulations on the application of Sec. 108(i), providing guidance to C corporations regarding the accelerated inclusion of deferred cancellation of debt income and accelerated deduction of deferred original issue discount.
Proposed Regulations Change Definition of R&D Expenditures
The IRS provided guidance on the treatment under Sec. 174 of research and development expenditures incurred in connection with the development of tangible property, including pilot models.
Qualified Small Business Stock: An Opportunity for Tech Startups
The existence of convertible debt, incentive stock options, warrants, and preferred stock, along with the need for additional capital, creates opportunities for tech companies to issue additional qualified small business stock in 2013.
Earnings and Profits Computation Case Study
It is important for businesses organized and taxed as regular corporations to maintain a current, accurate accounting of their earnings and profits (E&P).
R&D Tax Credits for Food and Beverage Companies
Food manufacturers should look closely at the R&D tax credit even if, in the past, they did not believe their activities in developing new products or processes qualified as technological research.
Sec. 199 Deduction and Contract Manufacturing Arrangements: Who Gets the Deduction?
The IRS issued new guidance to examiners in its Large Business & International Division regarding how to determine which taxpayer is entitled to claim the Sec. 199 domestic production activities deduction in a contract manufacturing arrangement.
Repair Regulations Are Finally Issued
The IRS issued long-awaited final and proposed regulations regarding the treatment of expenditures incurred in acquiring, producing, or improving tangible assets.
IRS Explains Sec. 179 Qualified Real Property Allocations and Procedures for Filing Amended Returns
The explained how the retroactive extension of the Sec. 179 rules operates when applied to qualified real property and how to allocate the portion of gain attributable to the qualified real property upon disposition or to calculate any carryover.
Proposed Regulations Change Definition of R&D Expenditures
In proposed regulations , the IRS provided guidance on the treatment under Sec. 174 of R&D expenditures incurred in connection with the development of tangible property, including pilot models.
Leveraging Existing ERP Systems to Automate Use Tax Compliance
Today’s corporate tax departments are questioning whether they really need expensive bolt-on software for use tax compliance.
ATNOLs and Charitable Contribution Carryovers: Which Takes Precedence?
The uncertainty surrounding the ordering rules of the 10% limit on the charitable deduction and the 90% limit on the ATNOL deduction has been affecting more corporate taxpayers as the economy recovers and these corporations start generating current-period taxable income.
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