Employer-provided and company-owned vehicles
General or special methods of valuing employer-provided vehicles are available for determining the employer’s and employee’s tax treatment of this fringe benefit.
Reporting & Filing Requirements
CFCs: US shareholders’ income inclusions
This item clarifies the various categories of income inclusions a U.S. shareholder of a CFC may need to consider to the extent of its current-year earnings and profits or deficits and how to properly report and track any foreign inclusions related to E&P.
Gain recognition agreements: US corporation’s transfer of a foreign corporation followed by the foreign corporation’s disposition of its assets
This item discusses the use of GRAs to defer tax on the outbound transfer of stock to a foreign corporation.
Deferral of penalties for failure to timely deposit employment taxes
The IRS determined that a failure to deposit any portion of the federal employment taxes deferred by the CARES Act by the applicable installment due date will result in a penalty.
Voluntary carbon offsets: The evolution of a business expense
This article discusses the disclosure and reporting of VCOs and whether VCOs should be treated as deductible ordinary and necessary business expenses, capitalizable expenses, deductible charitable contributions, or nondeductible expenses.
Seven strategies to accelerate income in response to increasing rates
Due to concern about tax rate increases, some taxpayers may be looking to accelerate income. While income acceleration does not make sense in all circumstances, this article outlines seven strategies for accelerating income when it does.
Corporation not covered by economic hardship exception
The economic hardship exception to a levy does not apply to corporations.
Automatic procedures to change a CFC’s depreciation method
The IRS issued Rev. Proc. 2021-26, which contains procedures for certain foreign corporations to obtain automatic consent to change their methods of accounting for depreciation to the alternative depreciation system.
The current state of evolution of cryptoasset taxation
Recently released IRS Chief Counsel Advice targeted at the BTC/BCH hard fork also provides insight into how the IRS may evaluate more complex cryptoasset transactions.
Virtual currency update
Treasury takes a more aggressive stance on reporting of virtual currency transactions.
Penalty relief for Forms 5471, 5472, and 8865
Various options are available for mitigating penalties for noncompliance with foreign return filing requirements.
Revisiting withholding on equity compensation
In the time of COVID-19, where employers may increasingly turn to equity compensation to save on cash compensation expenses and employees are increasingly mobile, there is increased risk for employers.
Several states provide one-month filing relief for corporate deadlines
With the Oct. 15 corporate tax filing deadline looming and the global pandemic still affecting taxpayers and practitioners, several states have provided one-month filing relief for their corporate Oct. 15 deadlines.
Consolidated groups get NOL guidance
The IRS issued proposed and temporary regulations explaining how consolidated groups should apply the changes to the net operating loss rules enacted by the CARES Act.
Supreme Court overturns consolidated group tax refund allocation rule
The U.S. Supreme Court struck down the Bob Richards rule for allocating tax refunds among members of a consolidated group, holding that state law is well equipped to decide the matter.
Rethinking NOL waivers by a consolidated group
Now that NOL carryforwards are unlimited for tax years beginning after Dec. 31, 2017, practitioners should be rethinking the use of the waiver of NOL carryforwards under Regs. Sec. 1.1502-32(b)(4) in acquisitions of a company with NOLs by a member of a consolidated group.
Certified professional employer organization rules finalized
Certified professional employer organizations enter into contracts with employers to be treated as the employer for employment tax purposes and are subject to IRS rules in order to qualify as CPEOs and maintain that status.
Consolidated return regs. provide special return due-date rules for short tax years
This item discusses special return due-date rules for a target corporation’s short tax year when it joins a consolidated group.
Excise tax refunds for purchases of frequent flyer miles
Banks, hotel groups, large retailers, utilities, and car rental companies may be eligible for refunds of federal excise tax paid when purchasing frequent flyer miles from domestic airlines to use in reward and loyalty programs.
Rules for certified professional employer organizations finalized
Certified professional employer organizations (CPEOs) enter into contracts with employers to be treated as the employer for employment tax purposes and are subject to IRS rules in order to qualify as CPEOs and maintain that status.
