M&A pitfalls for deferred research expenditures
Treasury and the IRS have issued minimal guidance on current Sec. 174, and future guidance may provide more clarity or different results than what is detailed in this item.
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Treasury and the IRS have issued minimal guidance on current Sec. 174, and future guidance may provide more clarity or different results than what is detailed in this item.
Certain environmental cleanup costs, restaurant ‘smallwares,’ and certain vehicle replacement tires have expensing options that business owners may be unaware of.
The ruling, which is being obsoleted as of July 31, allowed a taxpayer that used the expense method for research and experimental expenditures to deduct on an amended return research and experimental expenditures the taxpayer did not deduct in prior years.
This item explores three types of compensation paid to employees of the target.
This item surveys four areas in which taxpayers face uncertainty in analyzing success-based fees.
The energy efficient commercial buildings deduction under Sec. 179D provides taxpayers with an incentive to make certain commercial building property more energy efficient.
Although the IRS has addressed several issues in the application of Sec. 384 with letter rulings and other guidance, the Service has yet to come out with comprehensive regulations and, thus, has yet to address several issues with its application.
This item summarizes some of the relevant authorities and then covers the facts and conclusion in Letter Ruling 202140002.
When is a company allowed to report as deductions on a tax return the expenses that have been incurred during the time leading up to getting the doors open for business?
Chief Counsel Advice provides insight to taxpayers planning or negotiating merger-and-acquisition transactions.
This item discusses the rules for deducting accrued liabilities in M&A transactions and then provides an illustration by looking at a recent IRS technical advice memorandum.
This item discusses business acquisitions that include assumption of deferred compensation costs and who — buyer or seller (or neither) — has a right to deduct those compensation amounts.
Modifications to Sec. 174 may affect other areas of taxation which must also be reflected in financial statements and estimated tax payments.
This article discusses a strategy to allow more interest to be deducted under the limitation involving the strategic adoption of FASB Accounting Standards Codification Topic 606, Revenue From Contracts With Customers.
A law change and some regulations take effect while an array of provisions expire.
This article discusses the disclosure and reporting of VCOs and whether VCOs should be treated as deductible ordinary and necessary business expenses, capitalizable expenses, deductible charitable contributions, or nondeductible expenses.
The IRS issued the annual update of the mileage rate taxpayers may use to compute their deductible automobile costs.
Microcaptive insurance arrangements have been vigorously scrutinized recently by the IRS.
The memo provides an analysis of the capitalization of amounts paid to acquire or create intangibles, providing insight into capital expenditures under Sec. 263 and trade or business expenses under Sec. 162, clarifying capitalizing vs. expensing.
Inbound structures involving interest or royalty payments by U.S. subsidiaries to foreign affiliates may trigger anti-avoidance rules where the foreign affiliates operate in countries that have notional interest deduction tax regimes.
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.