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.
Tax Planning; Tax Minimization
Improve fixed-asset management with technology
This item focuses on how to use technology to improve fixed-asset management.
The partner-to-partner attribution trap and the anti-churning rules
Taxpayers dealing with tax basis step-up transactions involving related parties or rollover equity interests should consider the application of the anti-churning rules to avoid unforeseen results.
Guide to expensing HVAC costs
This guide provides tax preparers an outline of questions to ask clients when evaluating HVAC repair costs.
Improving cash flow with loss carrybacks
This article discusses two planning areas related to NOL carrybacks: The decision whether to carry a
loss forward or back and planning strategies to increase the balance of the NOL carryback.
Farmers and real property trades or businesses can withdraw interest elections
Real property or farming trades or businesses can withdraw their decision to elect out of Sec. 163(j)’s business interest expense limitation for a 2018, 2019, or 2020 tax year.
Cost recovery changes in the TCJA
This article discusses changes to the law and IRS guidance issued in Rev. Proc. 2019-8 on how to elect to expense qualified real property and change the depreciation of certain assets to ADS.
Inflation adjustments affect small business limits, Sec. 179 expensing
Inflation adjustments for 2019 and 2020 may increase the number of taxpayers that qualify as a small business and the amount of costs that can be expensed under a Sec. 179 election.
Business interest expense election guidance for farming, real estate
Real property or farming trades or businesses can withdraw their decision to elect out of Sec. 163(j)’s business interest expense limitation for a 2018, 2019, or 2020 tax year, the IRS said in guidance.
A renewed chance to revisit old assets for repairs and maintenance expense
For the 2019 tax year, taxpayers and their accountants should seriously consider revisiting
repairs and maintenance when planning strategies for increased deductions.
Navigating tax changes with statistical sampling
When a tax department finds itself making burdensome determinations on a list of records, it may be time to consider a sampling approach.
Tax accounting for businesses after the TCJA: Some widely applicable and lesser-known changes
This item discusses certain TCJA changes to domestic provisions relevant to tax accounting.
Modification of variable prepaid forward contracts triggers gain realization
A Second Circuit decision may affect the analysis
of whether the modification of a derivative triggers gain or loss.
Solar panels: Basis and bonus depreciation
The allowance of depreciation and the energy credit
both depend on a taxpayer’s having basis in the property.
Inventory accounting for cannabis businesses: Sec. 280E and the impact of tax reform
Practitioners are more likely now than ever to be asked to consult with clients that may either be
considering or are currently involved, directly or indirectly, in a state-legal cannabis business.
Deducting deferred bonuses
Numerous rules and restrictions govern the timing
of deductibility of bonuses accrued in one year and paid in another.
IRS guidance addresses limitations on business interest expense
The IRS has issued initial guidance on the new rules governing the deductibility of business interest in Sec. 163(j), as amended by the Tax Cuts and Jobs Act of 2017.
Investment adviser’s inducement payments to shareholders are not intangibles
The IRS ruled that the inducement payments were otherwise deductible under Sec. 162 and were not capitalizable under Sec. 263(a).
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.
Market discount rules: In search of an escape route for distressed debt
Many times a taxpayer who has purchased distressed debt is unaware of the unfavorable results of the market discount rules.
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.