Topics

January 1, 2024

Proposed regulations would update rules for consolidated returns

Proposed regulations for corporations that file U.S. federal consolidated income tax returns would update guidance under Sec. 1502 for statutory changes made over the last 50 years, modernize and clarify language, and facilitate taxpayer compliance.

January 1, 2024

IRS expands fast track for some corporate letter rulings

A pilot program is made permanent, offering resolution of certain letter ruling requests by corporations within 12 weeks.

December 1, 2023

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.

November 29, 2023

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.

November 8, 2023

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.

October 31, 2023

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.

October 1, 2023

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.

August 7, 2023

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.

July 27, 2023

AICPA advocates for delay in BOI reporting requirements

Too many businesses are unaware of the beneficial ownership information reporting requirements, which will be a burden for small businesses, the AICPA told Congress.

March 1, 2023

New stock repurchase excise tax

The Inflation Reduction Act, P.L. 117-169, included a new Sec. 4501 that imposes an excise tax on certain repurchases of stock by publicly traded corporations.

February 24, 2023

Taxpayers in disaster areas of 3 states have until Oct. 16 to file returns

Taxpayers in most of California and parts of Alabama and Georgia have had their tax filing and payment deadlines further extended to Oct. 16. The postponement covers a wide variety of returns and taxes.

February 22, 2023

Final regs. expand company e-filing requirements

Final regulations require certain companies to e-file returns for tax years ending on or after Dec. 31, 2023, and lower the e-filing requirement threshold to 10 returns.

February 1, 2023

90-day deadline for filing Tax Court petition in deficiency case is jurisdictional

Deadline for filing a Tax Court petition in a deficiency case is jurisdictional.

January 25, 2023

New online portal available for businesses to file Forms 1099

Although available to businesses of any size, the IRS expects the new Information Returns Intake System to be especially useful to small businesses that now file paper Forms 1099.

January 23, 2023

FinCEN provides time estimates for compiling beneficial ownership details

FinCEN estimates that most companies will have a simple structure that will require 90 minutes per response, but complex entry filings will require much more time.

January 12, 2023

FinCEN proposes rules about access to beneficial ownership information

Proposed regulations under the Corporate Transparency Act address protocols for access to beneficial owner information by authorized recipients.

January 1, 2023

Chief Counsel memo clarifies the assessment period in multiyear Sec. 332 liquidations

A recent IRS Chief Counsel memo clarifies the assessment limitation period in multiyear Sec. 332(b) liquidations.

December 1, 2022

Despite unanswered questions, Tax Court ends long-running case

The Tax Court enters a new decision in a case despite an ambiguous appellate court mandate

December 1, 2022

Tax practitioner issues related to Sec. 1202 exclusion reporting

The lack of guidance and regulations and the unwillingness of some companies to provide information to shareholders places taxpayers and tax practitioners in a difficult situation.

November 1, 2022

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.