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.
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TOPICS
C Corporation Income Taxation
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.
Sec. 174(d) in M&As: Risks and opportunities
Taxpayers and advisers should focus on understanding the risks and maximizing the benefits of Sec. 174 when involved in M&A transactions.
FinCEN posts guide to help small businesses with BOI reporting
A new guide posted by the Financial Crimes Enforcement Network describes BOI rules, answers questions, and provides tools to assist with compliance with the BOI reporting rules.
Guidance issued on applicability and calculation of new corporate AMT
In advance of proposed regulations, the IRS provided interim guidance to help corporations determine whether they are subject to the new corporate alternative minimum tax and how to calculate the tax, including how to determine financial statement income and applicable financial statement income.
Liquidating a controlled subsidiary tax-free
A parent corporation does not recognize gain or loss on its subsidiary’s liquidation and can succeed to certain of its tax benefits.
Integrating transfer pricing and ESG: Practical considerations
This item outlines a framework and approach for in-house tax professionals to consider when endeavoring to align transfer pricing operations within the broader context of ESG strategy.
Proposed regulations update, revise consolidated return regulations
New proposed regulations would update the regulations to reflect 50-plus years of statutory changes, remove regulations and certain transition rules that no longer have practical application, and eliminate obsolete or incorrect terms and cross-references.
Credit for increasing research activities in a short tax year
How a short year affects the determination of the credit for increasing research activities under Sec. 41 is often an afterthought for many taxpayers and their tax advisers.
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.
