Determining gross receipts under Sec. 165(g)(3)
This item summarizes some of the relevant authorities and then covers the facts and conclusion in Letter Ruling 202140002.
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This item summarizes some of the relevant authorities and then covers the facts and conclusion in Letter Ruling 202140002.
On Aug. 15, 2022, the IRS announced that it intends to defer by one more year the applicability date of certain foreign currency regulations under Sec. 987.
Taxpayers should strongly consider these letter rulings when trying to determine whether they want to structure a borrowing with a regarded entity as the legal borrower or whether they prefer to have a DRE be the legal borrower of the debt.
Right now, some basic tax planning ideas can make a significant difference in reducing income tax, thereby increasing cash flow and even creating tax refund opportunities.
Taxpayers whose overall tax position in a given year would benefit from accelerating gross income or from converting current deductions into capital expenditures should consider the elective capitalization provisions of Sec. 266.
The proposed regulations clarify the elections available to all taxpayers regarding bonus depreciation.
This item discusses a methodology to sample expenditures by reviewing amounts capitalized for book purposes and to determine the extent to which they should be classified as tangible personal property or expensed for tax purposes.
In addition to extending bonus depreciation and phasing out the bonus rate, the PATH Act made several changes to the types of eligible property under Sec. 168(k)(2).
Congress made a notable change to the definition of qualifying property for bonus depreciation purposes.
Here are some suggestions to help business clients reduce 2015 taxes by accelerating deductions into this year and delaying income until next year.
In Stine, LLC, No. 2:13-cv-03224 (W.D. La. 1/27/15), a retailer's store buildings were considered "placed in service" for federal tax depreciation purposes when they were "substantially complete" rather than when they subsequently were "open for business" resulting in the taxpayer's being able to take an accelerated depreciation deduction for the buildings. This decision highlights the importance of properly identifying an asset's placed-in-service date.
This item highlights several important aspects of the final tangible property regulations and related transition guidance that may affect cost-segregation studies and resulting changes in accounting methods.
General asset accounts provide a valuable simplification tool for tracking tangible assets and present some tax planning opportunities.
IRS released guidance related to the tangible property regulations regarding depreciation and dispositions.
If business vehicles are passenger automobiles, they are listed property and are subject to limits on the amount that can be deducted for regular depreciation, as a bonus depreciation allowance, and as a Sec. 179 expense.
New tangible property regulations apply to all current and certain prior-year tangible assets, creating compliance efforts and opportunities for immediate and long-term tax savings.
The IRS issued final regulations providing rules for how to determine gain or loss when property subject to depreciation is disposed of, how to determine the asset disposed of, and how to account for partial dispositions of depreciated property.
The IRS issued the 2014 inflation adjustments to the depreciation limitations and lease inclusion amounts for certain automobiles under Sec. 280F.
This article discusses the rules that must be followed to use the principle of cost segregation in any form.
The IRS issued the 2014 inflation adjustments to the depreciation limitations and lease inclusion amounts for certain automobiles under Sec. 280F.
DEDUCTIONS
Business meal deductions after the TCJA
This article discusses the history of the deduction of business meal expenses and the new rules under the TCJA and the regulations and provides a framework for documenting and substantiating the deduction.
TAX RELIEF
Quirks spurred by COVID-19 tax relief
This article discusses some procedural and administrative quirks that have emerged with the new tax legislative, regulatory, and procedural guidance related to COVID-19.