Reporting & Filing Requirements
This item discusses the use of GRAs to defer tax on the outbound transfer of stock to a foreign corporation.
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.
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.
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.
The economic hardship exception to a levy does not apply to corporations.
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.
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.
Treasury takes a more aggressive stance on reporting of virtual currency transactions.
Various options are available for mitigating penalties for noncompliance with foreign return filing requirements.
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.
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.
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.
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.
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 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.
This item discusses special return due-date rules for a target corporation’s short tax year when it joins a consolidated group.
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.
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.
This item discusses how an ELA can occur and potential methods to minimize or eliminate these balances before they are recaptured into taxable
The TCJA significantly broadened the application
of loss limitation rules.