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.
Tax Compliance
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.
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.
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.
Accelerating deductions with payroll tax accruals
This item focuses on how payroll tax accruals might be deducted in 2017 rather than 2018 without additional costs for the employer and no adverse tax consequences for the employees.
Accelerating FICA and FUTA Tax Deductions for Vacation and Bonus Pay
Rev. Rul. 2007-12 holds that if the all-events test and recurring-item exception of Sec. 461 are otherwise met, an accrual-method taxpayer may deduct FICA and FUTA tax expenses (payroll taxes) in the year that the deferred compensation to which they relate is earned, regardless of whether that deferred compensation is deductible in a later year under Sec. 404.
Accrued Payroll Tax Liability Is Deductible Even If Compensation Is Deferred Under Sec. 404
A recent ruling states that accrual-method taxpayers may deduct payroll tax liability incurred in the current year, for compensation deferred and deductible in the following year, under Sec. 404, provided the all-events test and recurring-item exception of Sec. 461 are met. Facts X, a corporation, uses an accrual method of
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.
