The exemption to the limitation on business interest under Sec. 163(j) does not apply to a tax shelter prohibited from using the cash-receipts-and-disbursements method of accounting under Sec. 448(a)(3).
C Corporation Income Taxation
The TCJA has given a windfall benefit to foreign investors and developers in U.S. real estate due to the drop in the corporate tax rate from 35% to 21%.
Shareholders can reap several benefits by leasing property to their corporation instead of transferring ownership to the company.
The challenge taxpayers frequently face is determining the date of sale, abandonment, or worthlessness.
The IRS’s LB&I division implemented a major restructuring intended to make better use of IRS resources.
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.
The order announcing the withdrawal says it is being done “to allow time for the reconstituted panel to confer on this appeal.”
Foreign-derived intangible income deduction: Tax reform’s overlooked new benefit for U.S. corporate exporters
One new opportunity created by the TCJA is the foreign-derived intangible income deduction in Sec. 250(a).
The IRS issued proposed regulations on the Sec. 965 transition tax that requires U.S. shareholders of deferred foreign income corporations to pay tax on post-1986 deferred income.
This item discusses provisions of the TCJA that seek to curb the erosion of the U.S. tax base.
With the increased use of stock acquisitions, buyers must correctly apply the Sec. 382 limitations, including the additional analysis to determine the impact of NUBIG and NUBIL.
In the typical closely held business context, the TCJA’s reduction of corporate tax rates to a flat 21% is far from a panacea.
The Ninth Circuit reversed a Tax Court decision invalidating a cost-sharing regulation that requires allocation of stock-based compensation costs between related parties.
A successor law firm was given credit for the employment tax payments of its predecessor under the doctrine of equitable recoupment.
This discussion provides insight into planning opportunities to avoid the trap of unwinding a dividend.
This item explores whether the toll charge might be treated as a recognized built-in gain under Sec. 382(h).
Some incentives used by state and local governments to attract corporations will now likely be income to the recipient corporation.
This article discusses how the TCJA altered corporations’ responsibilities and the potential compensation implications.
This discussion focuses on the federal excise tax treatment of DPFs and potential fuel tax credits that may be claimed for fuel used to operate DPFs.
Tax treatment of individual owners of bitcoin and other virtual currencies held for personal use or investment
Tax preparers will need to be proactive in helping their clients identify and report any potentially taxable transactions.