With their prospects for deferral or even exclusion of gains from certain investments in them, the newly created qualified opportunity zones offer an intriguing tax planning option for investors and a potential boon for distressed communities.
C Corporation Income Taxation
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.
Failure to properly complete all required fields on Form 8283, including the donor’s cost or other basis, could jeopardize the entire deduction with respect to the donated property.
The proposed regulations clarify the elections available to all taxpayers regarding bonus depreciation.
This article offers guidance on maximizing the use of corporate state NOLs, recording deferred tax assets and valuation allowances for them, and incorporating their value in the pricing of M&A transactions.
Taxpayers should carefully review the proposed regulations for relevant limitations and be mindful of how future guidance may affect their investments.
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.
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 released advice that concluded that an accrual-based taxpayer was entitled to deduct quarterly commitment fees paid related to its revolving credit agreement.
In a changing landscape, U.S. C corporation multinationals should consider reevaluating their value chain.
This item provides an overview of the Sec. 958 constructive ownership rules, explores the “glitch" and its consequences, and discusses planning options to mitigate the negative effects.
This article discusses the modifications made to Sec. 174 and Sec. 41, which will affect taxpayers’ R&D tax credit claims for tax years after Dec. 31, 2021.
Sec. 856(n)(1)(a) specifies that passive foreign exchange gain (as defined in Sec. 856(n)(3)) for any tax year is not gross income for purposes of Sec. 856(c)(2).
The proposed regulations effectively treat a consolidated group as a single entity for purposes of determining the sharing of tested loss.
The IRS can take advantage of several rules to ensure related-party transactions do not result in tax evasion or an improper reflection on income.
Sec. 45S requires that an eligible employer for purposes of claiming the family and medical leave credit must have in place a written policy meeting certain requirements.
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 LB&I identified 10 new campaigns that expand the focus areas under its issue-based examination program.