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.
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TOPICS
C Corporation Income Taxation
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.
Schedule M-3 Filing Requirement Reduced for Entities Below $50 Million in Assets
The IRS announced changes in the filing requirements for Schedule M-3, Net Income (Loss) Reconciliation, for certain corporations and partnerships.
IRS Addresses Sec. 199 Requirements for Packaging Manufacturer
The exception for packaging, repackaging, labeling, or minor assembly activities does not apply to disqualify the taxpayer’s sales receipts from meeting the MPGE requirement under Sec. 199.
Timing of Deductions for Subsidiaries Joining a New Consolidated Return
Under the consolidated return rules, special considerations apply when a subsidiary member (Sub) joins or leaves a consolidated group during the tax year.
Avoiding Income Tax Credit Recapture by a Corporation
A corporation that disposes of real property may be required to increase its tax liability via a recapture of the investment tax credit or the low-income housing credit.
International Tax Issues for Newly Multinational Corporations: A Due-Diligence Perspective
A taxpayer that ventures into international business by acquiring a multinational target may encounter a number of tax issues that could result in significant unanticipated tax liabilities.
Check-the-Box: A Trap for the Unwary
It has never been easier to effect the choice of operating as a sole proprietorship, partnership, or corporation for federal income tax purposes; however, sometimes unforeseen problems can result.
Bankruptcy and the Trust Fund Recovery Penalty
When a corporation fails to remit the withheld taxes to the government, the IRS looks through the corporation to the individual or individuals who are responsible for the failure.
Employment Tax Liability of Third-Party Agents Subject of Prop. Regs.
The IRS released proposed regulations under Sec. 3504 that would govern the liability for employment taxes when an employer designates an agent under a “service agreement” to pay its employees and to satisfy all employment tax obligations.
Regs. Issued on Asset Transfers to Foreign Corporations
The IRS issued final, temporary, and proposed regulations governing outbound asset transfers under Sec. 361.
Employers Have Additional Time to Claim Work Opportunity Tax Credit
The IRS announced that it is extending the time employers who want to claim the WOTC have to file the prescreening notice and certification request.
The Challenge of Contributing Off-Spec Food to Charity
Donations of “off-spec” food may not result in a charitable contribution deduction greater than the tax basis of the food inventory because of the difficulty of determining the proper tax basis and FMV for the food.
IRS Releases Final Regulations and Interim Guidance on Medical Device Excise Tax
Treasury published final regulations and additional interim guidance relating to the medical device excise tax.
2013 Automobile Depreciation Limits Released
The IRS on Monday issued the 2013 inflation adjustments to the depreciation limitations and lease inclusion amounts for certain automobiles under Sec. 280F.
Proactive Elections to Mitigate Sec. 382 Applicability
Sec. 382, which limits the use of NOL carryovers after an ownership change of a loss corporation, often comes as a rude surprise to corporations in the fields of technology, life sciences, pharmaceutical, and similar industries.
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