Andrea Gacki, director of the Financial Crimes Enforcement Network, reassured a House committee that the agency can act only against willful violations of the new beneficial ownership information reporting rule.
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TOPICS
C Corporation Income Taxation
Recapture of foreign loss does not exempt other gain from tax
Gain on the disposition of controlled foreign corporation stock, in excess of the amount of gain required to be recognized as foreign income to offset a taxpayer’s overall foreign loss under Sec. 904(f)(3), is not exempt from tax.
Digital asset question added to more forms for 2023 tax returns
IRS adds a question about digital assets to forms covering partnerships, corporations, S corporations, and estates and trusts.
Draft form, instructions posted for corporate AMT
The IRS instructions say that all corporations must file Form 4626, unless they fall under one of four exclusions, to determine whether they are an applicable corporation, and, if so, to calculate the tax.
LB&I announces updates to 2024 CAP program
Changes to the IRS’s Large Business and International Division’s Compliance Assurance Process program include making the Bridge Plus phase mandatory.
R&E expenses: Amortization if the company ceases to exist
In Notice 2023-63, the IRS offered guidance on deducting remaining amortized specified research or experimental expenditures when applicable property is retired, abandoned, or disposed.
Energy credit prevailing wage and apprenticeship rules
The IRS and Treasury released a guidance package to help taxpayers engaged in qualified renewable energy projects comply with the prevailing wage and apprenticeship requirements created by the Inflation Reduction Act, P.L. 117-169.
The self-rental rules: Risks and opportunities
Be aware of the self-rental rules when a taxpayer owns an operating business and leases property to it through a separate entity that the taxpayer also owns. Self-rentals can create both tax planning risks and opportunities.
Proposed regulations would update rules for consolidated returns
Proposed regulations for corporations that file U.S. federal consolidated income tax returns would update guidance under Sec. 1502 for statutory changes made over the last 50 years, modernize and clarify language, and facilitate taxpayer compliance.
Apportioning tax benefits among members of a controlled group
A controlled group can choose how it apportions tax benefits and other items among its members, with rules for certain credits and for pension and profit-sharing plans.
IRS expands fast track for some corporate letter rulings
A pilot program is made permanent, offering resolution of certain letter ruling requests by corporations within 12 weeks.
Carbon sequestration payments are qualifying REIT income
An IRS letter ruling concluded that payments to a real estate investment trust for allowing a third party to permanently store CO2 underground on its timberlands were qualifying income for the purpose of the 75% and 95% gross income tests.
ERC voluntary disclosure program requiring 80% claim payback launched
The IRS announced the launch of a program that will allow businesses to repay money from questionable employee retention credit claims and avoid penalties and interest.
Final rule issued on access to beneficial ownership information
The director of the Financial Crimes Enforcement Network said the key changes from the proposed rule involve the scope of financial institution access to beneficial ownership information; limitations on offshore access to BOI; and streamlining procedures for state, local, and tribal law enforcement to gain access to BOI.
Interim guidance provided for the corporate alternative minimum tax
The IRS issued a notice on regarding the application of the corporate alternative minimum tax to shareholders of CFCs and to affiliated groups of corporations filing consolidated returns.
How compensatory intent affects compensation deductions
For a corporation to deduct a payment made to a shareholder/employee as compensation, compensatory intent must exist.
Time to clean up the fleet? Sec. 45W might help
While Sec. 30D is often the most well-publicized clean vehicle tax break, Sec. 45W offers a broader credit to businesses purchasing clean commercial vehicles.
Foreign corporations, controlled groups, and the gross receipts test
Major tax law changes in 2017 increased reliance on the gross receipts test and, in turn, the controlled group rules, making these sections a focal point for tax practitioners.
Tax Court allows equitable tolling of deadline to review CDP hearing
Equitable tolling applies to the deadline for filing a request for a collection due process hearing.
FinCEN extends BOI reports deadline for certain companies
Treasury’s Financial Crimes Enforcement Network extended the deadline to file beneficial ownership information reports from 30 days to 90 days for companies created or registered in 2024.
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.
