Expenses & Deductions
Sec. 250 allows domestic corporations a deduction for their “foreign-derived intangible income.” Proposed regulations that were issued earlier this year answer many outstanding questions regarding the calculation of this new deduction but also include documentation requirements that may prove onerous for some taxpayers.
The IRS issued methods for calculating W-2 wages for the Sec. 199A(g) deduction for agricultural and horticultural cooperatives, similar to the former Sec. 199 domestic production activities deduction.
Because of the considerable tax consequences, the new law will encourage plaintiffs and defendants to refrain from including a nondisclosure agreement in their sexual harassment settlements.
The IRS issued proposed regulations on the business interest expense limitation in Sec. 163(j), which was amended by the law known as the Tax Cuts and Jobs Act.
Recent events should give taxpayers greater confidence to include pilot model expenses as Sec. 74 expenses and R&D supply costs.
The Sec. 162(m) grandfather rule provides multiple opportunities outside of the exemption for performance-based compensation.
The IRS concluded that a derivative that referenced a stock index was “substantially similar or related
property” to the stock of an exchange-traded fund that held the components of the index.
The IRS concluded that a taxpayer was required to capitalize 100% of an investment banking fee because it failed to satisfy the documentation requirement for success-based fees under Regs. Sec. 1.263(a)-5.
The IRS released advice that concluded that an accrual-based taxpayer was entitled to deduct quarterly commitment fees paid related to its
revolving credit agreement.
Employer reimbursements made in 2018 of qualified moving expenses incurred prior to 2018 in connection with a move that occurred prior to Jan. 1, 2018, may be excluded from employees’ wages and gross income despite the suspension of the exclusion for tax years 2018 through 2025.
The IRS issued guidance on the deductibility of meal and entertainment expenses after the modification of Sec. 274 by the TCJA.
The IRS issued proposed regulations on the business interest expense limitation in Sec. 163(j), which was amended by the law known as the Tax Cuts and Jobs Act.
The IRS issued guidance regarding amended Sec. 162(m), which limits the allowable deduction for remuneration paid by any publicly held corporation to a covered employee to $1 million.
Essentially, for federal tax purposes, marijuana businesses pay income taxes on their gross profit instead of their net income because below-the-
line deductions are not allowed.
The IRS issued guidance on the deductibility of meal and entertainment expenses after the modification of Sec. 274 by the TCJA.
Depending on how a taxpayer’s ownership is structured, the sale of a partnership interest can have a Sec. 280G impact on partners or members that are C corporations.
The challenge taxpayers frequently face is determining the date of sale, abandonment, or worthlessness.
The IRS issued guidance regarding amended Sec. 162(m), which limits the allowable deduction for remuneration paid by any publicly held corporation to a covered employee to $1 million.
One new opportunity created by the TCJA is the foreign-derived intangible income deduction in Sec. 250(a).
This article discusses how the TCJA altered corporations’ responsibilities and the potential compensation implications.
