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.
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TOPICS
C Corporation Income Taxation
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.
IRS Issues New Final and Temporary Regulations on Outbound Reorganizations
The IRS recently issued temporary and final regulations addressing certain outbound transfers of property, indirect stock transfers, and certain outbound asset reorganizations.
IRS Reverses Itself on Applying 70% Safe-Harbor Deduction for Success-Based Fees to Certain Milestone Payments
The IRS offers an elective safe harbor to deduct 70% of qualified success-based fees, and while certain “milestone payments” common to acquisition transactions do not qualify for the safe-harbor election, certain “eligible milestone payments” do.
Defining Stock of Insolvent and Bankrupt Corporations
This article discusses the special rules and issues surrounding the classification of stock ownership of corporations that are insolvent or in bankruptcy.
Final Sec. 336(e) Regulations: Election for Qualified Stock Dispositions
The IRS issued final regulations under Sec. 336(e) allowing a domestic corporation to make an irrevocable unilateral election to treat the sale, exchange, or distribution of a domestic corporation’s stock meeting the 80% vote and value requirements of Sec. 1504(a)(2) within a 12-month disposition period.
NOL Carrybacks Limited by Excess Distributions
While practitioners typically think of the application of the CERT rules in cases of debt-financed distributions or stock acquisitions, the rules could apply even if the underlying transaction is not debt-financed.
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.
