New stock repurchase excise tax
The Inflation Reduction Act, P.L. 117-169, included a new Sec. 4501 that imposes an excise tax on certain repurchases of stock by publicly traded corporations.
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The Inflation Reduction Act, P.L. 117-169, included a new Sec. 4501 that imposes an excise tax on certain repurchases of stock by publicly traded corporations.
Two recent court cases involving the research credit examine the Sec. 41(d)(4)(H) funded-research exclusion.
This item surveys four areas in which taxpayers face uncertainty in analyzing success-based fees.
Key issues related to the corporate AMT FTC are unsettled and could have a significant effect on a taxpayer’s corporate AMT liability.
Taxpayers in most of California and parts of Alabama and Georgia have had their tax filing and payment deadlines further extended to Oct. 16. The postponement covers a wide variety of returns and taxes.
Final regulations require certain companies to e-file returns for tax years ending on or after Dec. 31, 2023, and lower the e-filing requirement threshold to 10 returns.
The IRS announced on Monday a new pilot phase Compliance Assurance Process (CAP) program called Bridge Plus to provide prefiling return review to some large corporate taxpayers in the Bridge phase.
This item summarizes some of the relevant authorities and then covers the facts and conclusion in Letter Ruling 202140002.
Companies must focus on how ESG initiatives affect financial performance, market position, and ability to execute strategy, and a key component should be tax policy and planning.
Deadline for filing a Tax Court petition in a deficiency case is jurisdictional.
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 reviews the most significant provisions of the TCJA and CARES Act affecting state corporate tax regimes and discusses state conformity issues that should be addressed by corporate taxpayers.
Although available to businesses of any size, the IRS expects the new Information Returns Intake System to be especially useful to small businesses that now file paper Forms 1099.
In the long run, an agreement with a taxing authority is often a wiser choice than traditional compliance and dispute resolution methods.
FinCEN estimates that most companies will have a simple structure that will require 90 minutes per response, but complex entry filings will require much more time.
Proposed regulations under the Corporate Transparency Act address protocols for access to beneficial owner information by authorized recipients.
This article provides a high-level summary of the changes and discusses their implications for taxpayers.
The IRS no longer requires examiners to follow a four-step process for determining whether a transaction complies with the economic substance doctrine before a penalty can be asserted under Secs. 6662(b)(6) and 6662(i).
A recent IRS Chief Counsel memo clarifies the assessment limitation period in multiyear Sec. 332(b) liquidations.
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.