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.
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TOPICS
C Corporation Income Taxation
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.
Guidance Clarifies When Dividends Are Qualified Performance-Based Compensation
The IRS ruled on whether dividends paid on restricted stock were qualified performance-based compensation excluded from the applicable employee remuneration to which the $1 million limitation on the deduction for compensation by publicly held corporations applies.
IRS Issues Regulations on “Expatriated Entities” Under Sec. 7874
The IRS issued final, temporary, and proposed regulations intended to prevent abusive corporate inversion transactions.
Golden Parachute Calculations: 10 Misunderstood Aspects of Secs. 280G and 4999
When a company experiences a change in control, the golden parachute rules are intended to discourage excessive compensation for “disqualified individuals” by imposing adverse tax consequences on both the company and the disqualified individuals.
Sidestepping Deferred Intercompany Gain
This item illustrates how transfers of items outside a U.S. consolidated group can trigger a deferred intercompany gain and suggests ways to avoid that result in certain situations.
Section 530 Relief for Worker Classification Controversies
This article reviews the common law principles and authoritative guidance available to distinguish when workers are employees and the Section 530 safe-harbor provisions.
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.
