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.
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TOPICS
C Corporation Income Taxation
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.
Alternative Simplified R&D Credit Rules Finalized
The IRS has issued final regulations governing the election and calculation of the alternative simplified research and development credit. The regulations extend the election procedures for the alternative incremental research credit to the alternative simplified credit.
Final Regulations Simplify Accounting Rules in Corporate Reorganizations
The IRS issued final regulations intended to clarify and simplify rules concerning continuity of accounting methods and inventory methods in certain tax-free corporate reorganizations and liquidations.
Final Regulations Simplify Reduced Research Credit Election
The IRS released final regulations on July 26 further simplifying 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.
Employment Tax Consequences of a Corporate Change of Control Event
This item examines the employment tax consequences related to a corporate change of control event. Those consequences generally depend on the type of event, namely whether there is an asset purchase, a merger, or a stock acquisition.
One Reorganization, Two Tax Years, One Practical Solution
This item considers what is the proper time to report the transaction if a reorganization spans different tax years.
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.
