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.
C Corporation Income Taxation
The research credit: Funded research
Two recent court cases involving the research credit examine the Sec. 41(d)(4)(H) funded-research exclusion.
Uncertainties remain in analyzing success-based fees
This item surveys four areas in which taxpayers face uncertainty in analyzing success-based fees.
Corporate AMT: Unanswered questions about its foreign tax credit
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 disaster areas of 3 states have until Oct. 16 to file returns
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 regs. expand company e-filing requirements
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.
Some corporate taxpayers eligible for IRS CAP pilot on prefiling feedback
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.
Determining gross receipts under Sec. 165(g)(3)
This item summarizes some of the relevant authorities and then covers the facts and conclusion in Letter Ruling 202140002.
Marrying ESG initiatives to business tax planning
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.
90-day deadline for filing Tax Court petition in deficiency case is jurisdictional
Deadline for filing a Tax Court petition in a deficiency case is jurisdictional.
Recent changes to the Sec. 179D energy-efficient commercial buildings deduction
The energy efficient commercial buildings deduction under Sec. 179D provides taxpayers with an incentive to make certain commercial building property more energy efficient.
Issues in allocating income under Sec. 384
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.
Significant state conformity issues for corporate taxpayers
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.
New online portal available for businesses to file Forms 1099
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.
Advance pricing agreements: A realistic option for transfer pricing
In the long run, an agreement with a taxing authority is often a wiser choice than traditional compliance and dispute resolution methods.
FinCEN provides time estimates for compiling beneficial ownership details
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.
FinCEN proposes rules about access to beneficial ownership information
Proposed regulations under the Corporate Transparency Act address protocols for access to beneficial owner information by authorized recipients.
The Inflation Reduction Act’s energy- and climate-related tax provisions
This article provides a high-level summary of the changes and discusses their implications for taxpayers.
Memo removes IRS procedural requirements for economic substance arguments
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).
Chief Counsel memo clarifies the assessment period in multiyear Sec. 332 liquidations
A recent IRS Chief Counsel memo clarifies the assessment limitation period in multiyear Sec. 332(b) liquidations.
