The proposed regulations effectively treat a consolidated group as a single entity for purposes of determining the sharing of tested loss.
Reporting & Filing Requirements
This article discusses who qualifies to take the credit, how to make the election, the calculation and allocation of the credit, and how to report it.
To satisfy the Ilfeld standard, the court noted that there is a presumption that regulations do not permit double deductions for the same loss.
A successor law firm was given credit for the employment tax payments of its predecessor under the doctrine of equitable recoupment.
This discussion focuses on the federal excise tax treatment of DPFs and potential fuel tax credits that may be claimed for fuel used to operate DPFs.
Employees should have overarching guidance for their global assignment that includes international assignment agreements.
When group policies are purchased from foreign insurance companies, there may be federal insurance excise tax issues.
This column examines the meaning of the standard and discusses whether the economic substance doctrine still should be applied to a transaction that does not run afoul of the “with a view” standard.
The regulations under Sec. 108(i) provide special rules for consolidated groups.
This column reviews the advent of Schedule UTP, considers the applicable ethical rules, and offers some best practice tips for practitioners.
The so-called Cadillac plan excise tax is now scheduled to take effect in 2020.
Once all uncertain tax positions have been identified, FASB Accounting Standards creates a two-step process to recognize and measure the tax benefits arising from those positions.
The IRS ruled that a distributing corporation’s acquisition of an interest in a partnership was not an acquisition of a new or different business.
Proposed Regulations Would Provide Guidance for Allocation and Absorption of Losses on a Consolidated Return
Proposed regulations address an issue when there is a consolidated net operating loss.
The IRS on Thursday asked for feedback on whether frequent flier miles that are redeemed for anything other than taxable air transportation should be exempt from the Sec. 4261 excise tax.
Professional employer organizations (PEOs) provide comprehensive payroll, benefits, and human resource outsourcing solutions to unrelated third-party employers. PEOs are often also referred to as employee leasing companies or "co-employers." The model for providing those services, which has been relatively consistent for many decades, may change significantly because of recent legislation that will bifurcate PEOs into two categories.
Compliance With Short-Period Return Rules Can Stave Off Penalties and Rejection of Elections as Untimely
The unextended due date of the return of a domestic corporation, Form 1120, U.S. Corporation Income Tax Return, generally is the 15th day of the third month following the close of the corporation's tax year. However, when a target corporation joins the consolidated group of a purchasing corporation on a date other than the first day of the target corporation's tax year, the due date for the target corporation's short-period final return is determined without regard to the last day of the short period.
The IRS concluded that two professional corporations could file a consolidated return with another corporation, even though licensed professionals, not one of the members of the consolidated return group, were the actual legal owners of these PCs' stock, as required by state law.
IRS Disagrees With Tax Court on Ability to Designate Employment Tax Payments as Income Tax Withholding
The IRS announced in that it will not follow a Tax Court holding that an employer may designate payments of its employment taxes to the income taxes of specific employees.
The medical device excise tax with its complex regulations and reporting requirements essentially amounts to a sales tax on members of a targeted industry group regardless of whether they have profits.