After a cross-border merger or acquisition, related affiliates often integrate and use the acquired intangibles, such as new products or innovative features. To help executives manage the resulting transfer pricing risk, this article examines the treatment of acquired intangibles in post-acquisition related-party transactions.
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Tax Accounting
Access to energy: A ‘new’ intangible asset?
Some leases and other contracts for priority access to electricity needed for new technologies may require 15-year amortization under Sec. 197.
Financial reporting for tax complexity in divestitures
Considerations in accounting for income taxes can include choice of method and classification of assets and liabilities.
Navigating the Form 1099-DA reporting maze
Make sense of the new rules for digital asset reporting, including transition relief for 2025 and safe harbors going forward.
IRS removes associated-property rule from interest capitalization regulations
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.
Why LIFO, why now?
The convergence of accelerating inflation and heightened tariff costs creates optimal conditions for adopting LIFO, but taxpayers need to understand the benefits and act promptly.
Digital asset transactions: Broker reporting, amount realized, and basis
Final regulations provide comprehensive guidance for tax reporting of transactions involving these increasingly common assets, and the IRS has granted transition relief in key areas.
Applying updated ASC Topic 740 requirements for the income tax footnote
Case studies provide practice in applying the new FASB tax accounting standards for public business entities.
Income tax purchase accounting considerations for a stock acquisition
Business advisers can help guide clients through the tax and accounting considerations of a corporate sale or purchase.
Are you doing all you can to keep the cash method for your clients?
A passthrough entity business cannot use the cash method of accounting if it is classified as a syndicate. This article discusses this rule and ways a passthrough entity business that is currently not a syndicate can avoid being reclassified as one and losing the use of the cash method.
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.
Announcement 2024-40: A gift and a curse?
While expenditures may be qualified investments for the Sec. 48D advanced manufacturing investment credit, related grant agreements are not long-term contracts under Sec. 460, the IRS announced.
Deferred revenue: Transactional triggering events
Deferred revenue liabilities must be carefully considered in conjunction with taxable asset sales, contributions to capital, and classification elections.
Tax accounting method changes: Procedures and potential issues during an IRS exam
Tax practitioners should be familiar with the special rules that apply and issues that can arise when an accounting method change is made while a taxpayer is under IRS examination.
The closing date of an M&A transaction
The date on which a merger or acquisition closes for tax purposes depends on when the benefits and burdens of ownership transfer under the facts and circumstances.
A closer look at the costs of borrowing
Comparison of the accounting and tax treatment of interest expense may reveal crucial differences and lead to best practices for managing it.
Transfer pricing: The C-suite needs to be informed
CEOs need to understand the arm’s-length rules for transactions between commonly controlled entities because of the enormous amounts at stake in tax disputes, financial reporting risk from uncertain tax positions, and customs valuations.
Automatic consent to Sec. 174 accounting method changes modified
In a revenue procedure, the IRS amended the process for changes in tax years after 2021.
New prop. regs. limit taxpayers’ foreign currency elections
The regulations would promote consistency with filing requirements for controlled foreign corporations and limit certain elections regarding foreign currency gains and losses.
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.
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.
