The IRS on its website announced changes in the filing requirements for Schedule M-3 for certain corporations and partnerships.
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TOPICS
C Corporation Income Taxation
New Method for Determining Who Gets Sec. 199 Deduction Under Contract Manufacturing Arrangements
The IRS issued new guidance regarding how to determine which taxpayer is entitled to claim the Sec. 199 domestic production activities deduction in a contract manufacturing arrangement.
Final Rules on Acceleration of COD Income Deferral Are Issued
The IRS issued final regulations on the rules to accelerate COD income that taxpayers elected to defer over a five-year period when an applicable debt instrument was reacquired by the issuer or a related party in 2009 or 2010.
Questions on EINs in F Reorganizations Involving Disregarded Entities
Until the IRS issues clarifying guidance on whether a corporation that converts to an LLC always must retain its historic EIN, potential procedural conflicts may exist in relying on Rev. Rul. 73-526 to retain an EIN in an F reorganization.
ATRA Allows Taxpayers to Continue to Accelerate Certain AMT Credits
Under the provisions of ATRA, corporations or consolidated groups with AMT credits from pre-2006 tax years may continue to accelerate the use of these credits instead of claiming bonus depreciation for eligible qualified property.
Whether Incentives That Require Companies to Provide Jobs Should Be Treated As Nonshareholder Capital Contributions
Imposition of a jobs requirement should not by itself prevent a subsidy from qualifying as a nonshareholder contribution.
Failing Subchapter C Requirements to Avoid Nonrecognition Treatment
If a transaction satisfies the substantive tests for certain subchapter C nonrecognition provisions, can the taxpayer nonetheless achieve a taxable exchange by intentionally violating procedural requirements?
Options for Compliance With Worker Classification Rules
Determining proper classification of workers, either as independent contractors or employees, can be subjective and a challenge for employers.
LIFO Inventory Considerations When Making a C-to-S Conversion
A taxpayer valuing its inventory under the last-in, first-out (LIFO) method should consider two significant implications for taxable income when converting from a C corporation to an S corporation.
Schedule UTP: Update on IRS Findings
This item provides an overview of the IRS’s statistics on 2010 and 2011 Schedules UTP, Uncertain Tax Position Statement.
Foreign Branch Incorporation: Interaction of OFL, Branch Loss Recapture Rules
This item discusses the interaction between two recapture rules—OFL recapture and branch loss recapture—triggered by a branch incorporation.
Opportunity to Eliminate Certain Intercompany Gain
Groups can effectively eliminate the intercompany gain in certain circumstances, thereby reducing the possibility of inadvertently triggering intercompany gain and freeing taxpayers from the need to plan transactions so as to avoid a trigger.
Entities With Less Than $50 Million in Assets Get New Schedule M-3 Filing Rules
The IRS announced changes in the filing requirements for Schedule M-3, Net Income (Loss) Reconciliation, for certain corporations and partnerships.
Sec. 336(e) Election Regulations Are Issued
The IRS issued final regulations on the rules that apply when an election under Sec. 336(e) is made to treat the sale, exchange, or distribution of at least 80% of the voting power and value of a target corporation’s stock as a sale of all its underlying assets.
IRS Issues “No-Rule” Orders on Several Sec. 355 Transactions
The IRS recently put an abrupt halt to its ruling practice with respect to several transactions in the Sec. 355 area for which rulings had previously become routine.
The Repair Regulations: Considerations for “Downstream” Oil and Gas Businesses
The oil and gas industry faces numerous challenges in applying the fact-intensive rules of the so-called repair regulations to costs incurred to repair and maintain property during its service life.
Underwater Property and Like-Kind Exchanges
Qualifying for like-kind exchange treatment becomes more complicated if the property exchanged is “underwater”—that is, the debt on the property exceeds its fair market value.
IRS Addresses Treatment of M&A Transaction Costs and Success-Based Fees
Taxpayers that incur costs relating to an acquisition or restructuring transaction must generally capitalize the costs that “facilitate” the transaction.
Asset Transfers to Foreign Corporations
The IRS issued final, temporary, and proposed regulations governing outbound asset transfers under Sec. 361.
Final Regulations for Sec. 336(e) Elections Are Issued
The IRS issued final regulations on the rules that apply when an election under Sec. 336(e) is made.
INDIVIDUALS
Current Developments in Taxation of Individuals: Part 1
This update surveys recent federal tax developments involving individuals, including court cases, rulings, and guidance issued during the six months ending October 2025.
