The organization highlighted top technical issues across 10 areas and urged the IRS to prioritize tax simplification.
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Topics
Tax Planning; Tax Minimization
Gray areas of Sec. 1202 warrant regulatory guidance
While recent legislation has further boosted the benefits of the qualified small business stock gain exclusion, official guidance is needed to clarify ambiguities.
Practical tax issues related to qualified reopenings
Treating multiple debt instruments as a single issuance under Sec. 1275 and its regulations can have tax advantages but is often overlooked.
Tax planning for health care management services organizations
Management service organizations, common in the health care industry, can provide certain tax advantages.
The close of deferral: Planning for the QOZ end game
Many investors in qualified opportunity zones face a large upcoming tax hit when their QOZ deferral ends. They should consider harvesting stock market losses in advance of it.
Sec. 280G and the evolving executive compensation landscape
The affiliated-group rules and other complications can require care in determining application of this excise tax on compensation paid in connection with a change of corporate control.
Tax considerations for foreign investment in US private credit
Foreign investors should carefully analyze tax implications and strategies before investing in the growing U.S. market for nonbank credit.
Seller beware: Repossessions in real estate installment transactions
Sellers financing a sale of real property are subject to gain recognition under Sec. 1038 if they repossess the property upon the buyer’s default.
Sec. 163(j) planning considerations
Businesses can explore several options to mitigate the interest deduction limitation under the Tax Cuts and Jobs Act.
Avoiding passive loss limitations on rental real estate losses
Strategies for using the $25,000 offset for rental real estate losses can include keeping income within its phaseout range and contributing the loss activity to a closely held C corporation.
Revisiting FIRPTA and return-of-capital distributions
Although the Foreign Investment in Real Property Tax Act applies to foreign holders of U.S. real property interests, U.S. real property holding corporations also may find it advantageous to apply for a withholding certificate.
Apportioning tax benefits among members of a controlled group
A controlled group can choose how it apportions tax benefits and other items among its members, with rules for certain credits and for pension and profit-sharing plans.
Aggregation rules affecting foreign-owned companies
Multinational businesses should carefully consider whether the aggregation rules may trigger the application of unfavorable tax rules for their U.S. subsidiaries.
Sec. 174(d) in M&As: Risks and opportunities
Taxpayers and advisers should focus on understanding the risks and maximizing the benefits of Sec. 174 when involved in M&A transactions.
M&A transactions: The value of sell-side tax diligence
This item highlights how sell-side tax diligence can mitigate risks.
‘Blocker’ corporations: Considerations for investment fund managers
This item outlines several issues for fund managers to consider as they analyze how to use blocker corporations in their fund structures.
Inflation Reduction Act implications for Sec. 355 distributions
This item examines the implications for distributions described in Sec. 355(a) that follow from the introduction by the Inflation Reduction Act of the stock repurchase excise tax and the corporate alternative minimum tax.
Taxation of employees’ use of corporate apartments
The use of a corporate apartment as part of business travel generally could be excluded as a working condition fringe benefit, provided substantiation and other requirements are met.
What the Inflation Reduction and CHIPS acts could mean for US importers
This item discusses what the Inflation Reduction and CHIPS acts could mean for U.S. importers, beginning with the CHIPS Act.
Marrying ESG initiatives to business tax planning
Companies must focus on how ESG initiatives affect financial performance, market position, and ability to execute strategy, and a key component should be tax policy and planning.
INDIVIDUALS
Current Developments in Taxation of Individuals: Part 1
This update surveys recent federal tax developments involving individuals, including court cases, rulings, and guidance issued during the six months ending October 2025.
