The IRS published final regulations relating to how an entity serving targeted populations can meet the requirements to be a qualified active low-income community business under the provisions of the new markets tax credit program.
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TOPICS
C Corporation Income Taxation
A Cautious Approach to Sec. 163(l) in Common Private-Equity Lending
Fund financing can carry with it the potential for unintended tax consequences under Sec. 163(l)’s “disqualified debt” rules.
Determining Tax Consequences of Corporate Liquidation to the Shareholders
Under Sec. 331, a liquidating distribution is considered to be full payment in exchange for the shareholder’s stock, rather than a dividend distribution, to the extent of the corporation’s earnings and profits.
Investors’ Dilemma on Purchasing Distressed Obligations
This article discusses the purchaser’s perspective of an investment in distressed obligations that are secured by leases on tangible property.
Corporation Cannot Deduct California Business Privilege Tax in Year Paid
An accrual-basis taxpayer could not deduct the California business privilege tax in the year it was paid, even though California treated the tax as being incurred in that year.
R&D Tax Incentives Around the World
With the R&D credit in limbo, now is the time to reevaluate the entire system by looking at other countries’ R&D tax incentives.
Going Green Yields Immediate Tax Savings
Taxpayers may not be aware of many tax incentives are available at the federal, state, and local levels to defray the costs of energy-efficient equipment and systems.
IC-DISC Offers Tax Advantages for Closely Held Export Companies
For a closely held U.S. company engaged in export sales, an IC-DISC offers opportunities to both reduce the amount of revenue subject to the ordinary income tax rate and provide financial compensation to employees, shareholders, or other stakeholders.
Application of the Consolidated Tax Return Rules to Insolvent Members
The tax treatment of an insolvent debtor realizing discharge of indebtedness income under the U.S. consolidated income tax return rules can vary considerably depending on the particular circumstances.
IRS Issues Regs. on Sec. 7874 Expatriated Entities
The IRS issued temporary regulations governing whether a foreign corporation has “substantial business activities” in a foreign country compared to the total business activities of the expanded affiliated group
Now Is the Time: Converting a C Corporation to an S Corporation or LLC
The current uncertain economic environment may present an opportunity to exit C status and its attendant double taxation at an acceptable current tax cost.
Proposed Regs. Would Clarify Who Is Subject to Sec. 274(n) Limit on Meal Expenses
The IRS released proposed regulations clarifying which party is subject to the rule that limits the deduction for meals to 50% of the expenses incurred.
Regulations Finalize Rules 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.
New Rules Aim to Shut Down Certain Outbound Asset Reorganizations
The IRS issued rules to govern certain outbound asset reorganizations involving the transfer of intangibles under Sec. 367(d) that will apply instead of existing regulations
Federal Income Tax Treatment of Certain Transferable State Tax Credits
The emergence of online marketplaces and auction houses has provided a single point of contact for both sellers and buyers, making sales and purchases of transferable state tax credits more common.
Preparing for the Medical Device Excise Tax
Taxpayers may face a number of unresolved issues in preparing to comply with the new excise tax on sales of medical devices.
Employment Tax Liabilities of Foreign Entities
A number of technical questions are involved in determining status as an employer for federal employment tax purposes when a foreign business sends individuals to work in the United States.
Post-Deal Depreciation: Impact of Certain Nonrecognition Transactions
When planning an incorporation or reorganization transaction, taxpayers and their advisers may not examine in depth the related accounting method and depreciation issues that arise as a result of the transaction.
Using Sec. 338 to Avoid Anti-Churning Rules
When assets are sold in a taxable transaction, the buyer must be aware of limitations placed on amortizing certain acquired intangibles under the anti-churning rules; a recent ruling highlights the ability to use a Sec. 338 election to create the effect of an asset sale while avoiding the antichurning rules.
Taxing the Transfer of Debts Between Debtors and Creditors
Assumptions and other transfers of debt between corporations and shareholders or between partnerships and partners can often be tax free as part of a contribution, distribution, reorganization, or liquidation. This article analyzes several types of debt transfers and their potential for recognition of gain or loss and income from cancellation of debt.
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.
