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.
Advertisement
Topics
Reporting & Filing Requirements
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.
Penalty relief for Forms 5471, 5472, and 8865
Various options are available for mitigating penalties for noncompliance with foreign return filing requirements.
Virtual currency update
Treasury takes a more aggressive stance on reporting of virtual currency transactions.
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.
Considering the SRLY rules and Sec. 382 in the post-TCJA world
The TCJA significantly broadened the application
of loss limitation rules.
Managing excess loss accounts
This item discusses how an ELA can occur and potential methods to minimize or eliminate these balances before they are recaptured into taxable
income.
Proposed GILTI regs. provide useful guidance on certain consolidated return issues
The proposed regulations effectively treat a consolidated group as a single entity for purposes of determining the sharing of tested loss.
Using R&D credits to reduce payroll taxes: An overlooked opportunity for startups
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.
Third Circuit relies on Ilfeld doctrine to deny consolidated group deductions for duplicated losses
To satisfy the Ilfeld standard, the court noted that there is a presumption that regulations do not permit double deductions for the same loss.
employee benefits & pensions
Profits interests: The most tax-efficient equity grant to employees
By granting them a profits interest, entities taxed as partnerships can reward employees with equity. Mistakes, however, could cause challenges from taxing authorities.
