The most recent change to Schedule M-3, for 2010 and following tax years, requires new disclosures of research and development (R&D) costs and Sec. 118 exclusions from income of nonshareholder contributions to capital for corporate filers.
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TOPICS
C Corporation Income Taxation
Alternative Basis Step-up Transactions: Leveraging Disregarded Entities in an F Reorg.
The disregarded entity has created numerous opportunities for well-advised taxpayers to accomplish transactions that may not have previously been feasible.
Temporary Regs. on All-Cash D Reorgs Issued
The IRS issued temporary and proposed regulations governing the determination of the basis of stock or securities in a corporate reorganization when the issuing corporation does not distribute any stock or securities in the reorganization.
Witnesses Tell Congressional Subcommittee Small Business Health Tax Credit Is Too Complicated
A tax credit enacted to encourage small businesses and tax-exempt organizations to provide health insurance coverage for employees is too complicated and is not meeting its goal, witnesses told a congressional panel on November 15.
Revisiting the New Markets Tax Credit
Treasury has proposed revisions to the new market tax credit regulations to make the program more attractive to investors in non–real estate businesses in low-income communities.
Updated Guidance on the Determination of Basis of Stock in Transferred Basis Transactions
Rev. Proc. 2011-35 provides four safe-harbor methodologies that a corporation may use to establish its basis in the stock of another corporation in a type B reorganization or certain other transferred basis transactions.
100% Bonus Depreciation and the Corporate Election to Increase the Minimum Tax Credit Limitation
The Tax Relief, Unemployment Insurance Reauthorization, and Job Creation Act of 2010 extends the 50% bonus depreciation deduction to qualifying property placed in service through 2012. Congress also provided a 100% bonus depreciation deduction for qualified property acquired and placed in service after September 8, 2010, through December 31, 2011.
Final Regs. Eliminate Hot Stock Rule for Certain Reorganizations
The IRS issued final regulations that generally hold that the so-called hot stock rule is inapplicable in reorganizations where a subsidiary is a member of the distributing corporation’s separate affiliated group
Trade Bills Pass Congress with Tax Provisions
The EITC due diligence penalty will increase to $500 under a bill passed by Congress Oct. 12.
Shareholder Loan Documentation
This item explores the importance of paying attention to details and following document terms for shareholder loans.
Some Implications of 100% Bonus Depreciation
This item discusses optimization of the 100% bonus depreciation deduction, highlighting some of its implications and peculiarities.
Final Regs. Simplify Reduced Research Credit Election
The IRS released final regulations (T.D. 9539) that further simplify an election method by which taxpayers may use a standard rate to reduce a research credit under Sec. 41 in lieu of reducing their research expense deductions. The final regulations also clarify how members of a controlled group may make the election. The final regulations adopt with some modification proposed regulations issued in 2009 (REG-130200-08).
Accounting Rules in Corporate Reorgs. Simplified
The IRS issued final regulations (T.D. 9534) intended to clarify and simplify rules concerning continuity of accounting methods and inventory methods in certain tax-free corporate reorganizations and liquidations.
Final Regs. Govern Election to Deduct Business Start-up Expenses
The IRS issued final regulations (T.D. 9542) governing elections by individual taxpayers, corporations, and partnerships to deduct start-up expenses or organizational expenditures.
Transaction Cost Considerations: Rev. Proc. 2011-29 and Other Related Matters
To eliminate the controversy over the allocation of success-based fees and corresponding documentation requirements, Rev. Proc. 2011-29 povides a safe-harbor election for allocating 70% of success-based fees paid or incurred in a covered transaction to activities that do not facilitate the transaction.
Final Regs. Issued on Killer B Transactions
The IRS has issued final regulations to close a loophole (known as Killer B transactions) that allowed one or more foreign corporations involved in a triangular reorganization to repatriate earnings tax free to the United States in certain circumstances.
IRS Offers Another Mark-to-Market Valuation Safe Harbor
The IRS has released an Industry Issue Directive instructing its examining agents to offer a safe-harbor election to certain taxpayers under examination regarding the market values used in their mark-to-market calculations.
Election to Deduct Business Startup Expenses Gets Final Rules
The IRS issued final regulations governing elections by individual taxpayers, corporations and partnerships to deduct startup expenses or organizational expenditures.
Dispute Resolution Process for the 2011 Prescription Drug Annual Fee
This item describes the exclusive process available to covered entities to dispute the preliminary calculations of the annual fee on branded prescription drugs and obtain any change to data that would be reflected in the final fee allocation.
Claiming Bonus Depreciation on Self-Constructed Long Production Period Assets
This item discusses the process of claiming bonus depreciation on self-constructed long production period assets, with a focus on how the taxpayer can determine how the binding contract rules and placed-in-service rules apply to particular projects.
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.
