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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.

Deducting Payroll Taxes on Deferred Compensation

Editor: Mary Van Leuven, J.D., LL.M. The IRS recently determined that Sec. 461, rather than Sec. 404, governs the timing of the deduction for payroll taxes on deferred compensation by an accrual-basis taxpayer. Background Generally under Sec. 461(a), a deduction is taken into account in the proper tax year under

Deducting Executory Contract Expenses

Editor: Mary Van Leuven, J.D., LL.M. On Dec. 21, 2006, the IRS released Rev. Rul. 2007-3, which provides guidance on whether the execution of a contract for services or insurance (an executory contract liability) establishes the “fact of the liability” under Sec. 461. The determination of whether a contract for

Treatment of Capitalized Costs of Intangible Assets (Part II)

Executive Summary This two-part article provides an overview of cost recovery for intangible asset expenditures. Part II covers the income- forecast and units-of-production methods, computer software, transaction costs and Sec. 195 deductions. This two-part article examines how capitalized costs of intangible assets are recovered. Part I, in the April 2007

FIN 48 and R&D Tax Credits

Editor: Terence E. Kelly, CPA Under Financial Accounting Standards Board Interpretation No. (FIN) 48, Accounting for Uncertainty in Income Taxes, claims for research and development (R&D) credits are tax positions that companies following GAAP must evaluate to determine whether (and the extent to which) they may be recorded as a