A pilot program is made permanent, offering resolution of certain letter ruling requests by corporations within 12 weeks.
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TOPICS
C Corporation Income Taxation
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.
FinCEN will allow use of identifier in beneficial ownership reporting
Treasury’s Financial Crimes Enforcement Network (FinCEN) made changes to its beneficial ownership information reporting rule in response to comments to a proposed rule.
Home office and other business expenses denied
It is essential to emphasize the importance of substantiation to clients and to make sure they understand the substantiation requirements and to educate clients on how to maintain accurate recordkeeping and to record transactions in real time.
Navigating around limits on meals and entertainment
Deductions may be claimed for business-related meals and entertainment if taxpayers heed these rules and limitations.
Substantiation of business expenses: A review of the basics
A recent Tax Court case highlights the fact that taxpayers bear the burden of substantiating not only the amount of the deduction but also that the purpose underlying the deduction is ordinary and necessary to operating their trade or business.
AICPA, others call for a one-year extension of BOI report deadline
In a letter to Treasury’s Financial Crimes Enforcement Network, the AICPA says the additional time will give all businesses a fair and reasonable time frame to become aware of the new and complex rule.
FinCEN continues outreach on BOI reporting, may release YouTube videos
The new head of the Financial Crimes Enforcement Network said the online videos, which she used in her previous government position, are among the communication options being considered to inform companies about beneficial ownership information reporting requirements.
The true cost of ERC noncompliance
The eligibility requirements for the ERC are strict, despite dubious assertions that all employers qualify, propelled by a manufactured fear of missing out.
Defining software development costs
Software development costs that historically may not have been identified as qualified research expenditures for purposes of the Sec. 41 tax credit for increasing research activities need to be identified to comply with the capitalization requirement under Sec. 174.
Aggregation rules affecting foreign-owned companies
Multinational businesses should carefully consider whether the aggregation rules may trigger the application of unfavorable tax rules for their U.S. subsidiaries.
Beneficial ownership information reporting: Right around the corner
Clients should start developing procedures and policies to comply with the new reporting requirement and begin to gather the data that will be necessary.
employee benefits & pensions
Profits interests: The most tax-efficient equity grant to employees
By granting them a profits interest, entities taxed as partnerships can reward employees with equity. Mistakes, however, could cause challenges from taxing authorities.
