The invalidation by the Federal Circuit of the rule and its removal by the IRS affect the treatment of interest on certain improvements to designated property.
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Tax Computation
The enduring importance of determining tax ownership
Throughout nearly a century of case law and guidance, the benefits and burdens of ownership have remained the touchstone for claiming tax attributes of tangible property.
Navigating the complex interplay between Secs. 108(e)(6) and 367(c)(2)
A common method of resolving intercompany debt can entail ambiguity when a foreign subsidiary is involved, due to a dearth of regulatory guidance.
Tax implications in the automotive industry: The core of remanufacturing
Remanufactured “cores,” or used vehicle parts, are essential to the automotive industry but present distinct special tax and accounting considerations.
Planning opportunities: Sec. 179 expensing vs. bonus depreciation
As bonus depreciation phases out, practitioners need to consider Sec. 179 expensing to maximize deductions on fixed-asset purchases.
Bonus depreciation phaseout planning
With bonus depreciation phasing out through 2027, taxpayers have an opportunity to review their accounting methods with regard to fixed assets to ensure they are using the best methods.
Lenders’ tax consequences of foreclosure
Third-party creditors holding defaulting loans need to understand calculating gain or loss and whether it is ordinary or capital in foreclosure and deed-in-lieu of foreclosure proceedings.
Electing the UNICAP historic absorption ratio under the modified simplified production method
To avoid contending with the complex and time-consuming calculations of the uniform capitalization rules under Sec. 263A, taxpayers may want to consider electing the historic absorption ratio with this method.
Dual consolidated losses: Recapture considerations
An interesting issue can arise when a corporation must recapture dual consolidated losses on the sale of a foreign entity.
Defining software development costs
Software development costs that historically may not have been identified as qualified research expenditures for purposes of the Sec. 41 tax credit for increasing research activities need to be identified to comply with the capitalization requirement under Sec. 174.
A UNICAP exception for real estate development
This item focuses on how real estate owners that develop, hold, and rent their own property can benefit from an exception to Sec. 263A uniform capitalization requirements if they qualify as “small businesses.”
Including common improvement costs in real property basis
The IRS recently released Rev. Proc. 2023-9, which provides guidance for real estate developers to determine when common improvement costs may be included in the basis of individual units of real property held for sale.
The inadvertent-error exception to identifying hedging transactions
If taxpayers make a good-faith effort to comply with the hedge identification rules, then most unidentified hedges would likely have at least an argument for inadvertence.
Pillar 2: Time for US multinational enterprises to act
Large U.S. multinationals can take steps now to assess the potential impact of the global top-up corporate tax system that appears on the verge of being implemented.
Determining gross receipts under Sec. 165(g)(3)
This item summarizes some of the relevant authorities and then covers the facts and conclusion in Letter Ruling 202140002.
Auto depreciation limitations make a big leap for second year in a row
The IRS issued sharply higher new depreciation limitations for passenger automobiles, including those for which bonus depreciation is applied.
Sec. 987 foreign currency regulations applicability date extended again
On Aug. 15, 2022, the IRS announced that it intends to defer by one more year the applicability date of certain foreign currency regulations under Sec. 987.
Depreciation recapture in the partnership context
This item discusses how depreciation recapture applies in certain situations involving partnerships.
Auto depreciation limits leap with inflation
The Internal Revenue Service issued its annual inflation-adjusted update of depreciation limitations for passenger automobiles, including passenger vans and trucks, placed in service in 2022.
LB&I provides insight into Sec. 263A computations for resellers
This item outlines the general provisions of Sec. 263A, including special rules and exceptions for resellers, and provides insight into a reseller’s uniform capitalization calculation that may be areas of focus during an IRS examination.
TAX PRACTICE MANAGEMENT
2025 tax software survey
AICPA members in tax practice assess how their return preparation software performed during tax season and offer insights into their procedures.
