Early guidance for the new Sec. 45Z clean fuel production credit raises concerns regarding the eligibility of fuel sales to wholesalers.
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TOPICS
C Corporation Income Taxation
Federal excise tax traps for the unwary
Editor: Mary Van Leuven, J.D., LL.M. The U.S. government imposes federal excise taxes that can affect a surprising variety of companies. These taxes include the foreign insurance excise tax, the Patient–Centered Outcomes Research Institute (PCORI) fee, and the relatively new stock repurchase excise tax. Compliance with these taxes can be
Global expansion of e-invoicing and digital reporting obligations for nonresidents
Countries are expanding e-invoicing and digital reporting obligations to nonresidents to increase value-added-tax compliance.
Strategic trade management in 2025: Navigating and mitigating tariffs
As tariffs continue to affect costs, U.S. importers can employ these strategies to minimize their duty exposure.
CHIPS Act final regs. offer many taxpayer-friendly provisions
Congress incentivized domestic manufacturing of semiconductors and semiconductor manufacturing equipment as part of the Creating Helpful Incentives to Produce Semiconductors (CHIPS) Act of 2022.
AICPA makes Priority Guidance Plan recommendations to IRS
In addition to its 183 recommendations for the IRS plan, the AICPA encouraged the agency to continue to pursue tax simplification.
Appeals court leaves tariffs in place, seeks expedited argument schedule
A federal appeals court extended its stay of a nationwide injunction on tariffs imposed by a trade court and proposed a schedule that would include oral arguments on July 31 in the challenge to the president’s authority.
The proposed PTEP rules: Tax basis considerations under Sec. 961
Proposed regulations for previously taxed earning and profits of foreign corporations address a range of considerations for shareholder basis adjustments.
Using transfer pricing to blunt the effects of tariffs
Understanding the interrelationship of transfer pricing and tariffs is key to mitigating the effect of those levies on earnings.
Disregarded-payment-loss rules: How multinationals should prepare
New final regulations pose significant implications for possible income inclusions by U.S. corporations with foreign disregarded entities.
Simplified method to determine corporate AMT applicable status issued
A notice issued by the IRS with interim guidance for the application of the corporate alternative minimum tax offers an optional simplified method for determining applicable corporation status under Sec. 59(k).
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 planning for health care management services organizations
Management service organizations, common in the health care industry, can provide certain tax advantages.
Apportioning tax benefits among members of a controlled group
Maintaining an apportionment plan among component members can help ensure optimal tax results.
Elections under the new Sec. 987 final regs.
Businesses with foreign branches receive new guidance on adjusting for currency exchange gain or loss.
Placing in service the benefits of the Inflation Reduction Act
Determining when energy property is eligible for a tax credit or deduction hinges on when it is first placed in service, which can be controversial.
Legacy clean-energy credits evolve into tech-neutral credits
The transition beginning in 2025 entails certain new requirements but also opportunities.
Combining debtor and creditor positions: COD income considerations
Cancellation-of-debt income arises in a variety of merger-and-acquisition contexts, often with unclear tax treatment.
Treatment of digital assets transferred to employees
Sec. 83 governs the tax treatment of digital assets that employees receive in connection with their performance of services.
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.
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.
