A business can expense 70% of “success-based fees,” meaning amounts that are contingent on the successful closing of a covered transaction. It is important to remember this safe-harbor election can apply to both sides of the transaction.
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TOPICS
C Corporation Income Taxation
Rehabilitation Credits Disallowed
The Third Circuit held that a corporate partner in a partnership was not entitled to claim historic rehabilitation credits passed through to it from the partnership because the corporation was not a bona fide partner in the partnership.
Crop Insurance Proceeds: Appropriate Tax Planning Strategies
The severe drought experienced by much of the United States this year, especially in agricultural regions, is expected to produce a record number of crop insurance claims.
Measuring Insolvency Under Sec. 108
While determining if a taxpayer is bankrupt is straightforward, determining whether a taxpayer is insolvent can be tricky.
Rev. Proc. Updates Guidance on Adequate Disclosure of Return Positions
The IRS released its annual update identifying when a taxpayer’s disclosure of an item or position in an income tax return is adequate for purposes of reducing the understatement of tax penalty and the tax return preparer penalty for understatement due to unreasonable positions.
R&E Credit Opportunities for the Construction Industry
Taxpayers in the construction industry may want to consider the Sec. 41 research credit.
Controlled Groups and Deductibility of Patronage Dividends
CCA 201228035 addresses specifically the tax treatment of patronage dividends among related parties and/or controlled groups.
IRS to Allow Automatic Accounting Method Changes in Corporate Reorganizations
The IRS announced a change in its policy on automatic accounting method changes in corporate reorganizations.
IRS Announces Inflation Adjustments for 2013
The IRS released its annual revenue procedure making inflation adjustments to the gift tax annual exclusion and other items for tax years beginning in 2013.
Depreciation and Changes in Use of Real Property
This item discusses the distinction between residential and nonresidential property, depreciation, and the application of the change-in-use regulations if a rental property changes from residential use to nonresidential or vice versa.
Payments to Related Entities Are Dividends, Fail Independent-Investor Test
The Seventh Circuit held that a C corporation’s payments to entities owned by its shareholders for consulting services were disguised dividends.
Schedule UTP: IRS Findings
Recent data show what the IRS has found regarding Schedule UTP filings by corporations with $100 million or more of total assets on their tax return balance sheets, and what the IRS is doing with that information.
How Changes in Corporate Tax Rate Can Affect Choice of C vs. S Corp.
This item examines the effect of the proposed lower corporate tax rates in an analysis of the tax results of converting an S corporation to a C corporation.
Final Regs. Issued on Entertainment Use of Business Aircraft
The IRS issued final regulations relating to the disallowance under Sec. 274 of deductions for the use of business aircraft for entertainment (T.D. 9597).
Tax Court Defines Gross Receipts for the Research Credit
The Tax Court clarified that nonsales income is included in gross receipts for purposes of the Sec. 41 research credit.
Corporate Equity Reduction Transaction Guidance Issued
The IRS issued proposed regulations governing the availability of NOL deductions that are attributable to corporate equity reduction transactions.
Automatic Accounting Method Changes to Be Allowed in Corporate Reorganizations
The IRS announced a change in its policy on automatic accounting method changes in corporate reorganizations.
Deductibility of LEED Certification Costs
Tax professionals may be in the best position to support their clients or company in identifying LEED certification costs and determining the appropriate tax treatment as either a current-period expense or a capital expenditure.
Deducting Losses on Worthless Investment Securities
Understanding the rules for deducting losses on worthless securities is necessary to determine the correct timing of the loss deduction.
Corporate Financing Companies: Treatment of Losses
Financial blocker entities are used as a mechanism to prevent funds from potentially being engaged in a U.S. trade or business.
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.
