C Corporation Income Taxation
To facilitate the transition away from IBORs and minimize the resulting market disruption, the IRS
issued the proposed regulations with an aim of reducing associated tax uncertainty and taxpayer burden.
This discussion provides an overview of the current Sec. 382 regime, and then discusses the significant
changes in the proposed regulations and their implications.
This article explores the competing perspectives and discusses the IRS’s interim guidance on the deductibility of business meals.
A company acquired by another company cannot take a deduction for a fee from the acquisition transaction that it paid on behalf of the acquiring company.
This article discusses the areas that may continue to
pose TCJA implementation challenges for companies.
The IRS issued proposed regulations on the Sec. 162(m) $1 million limit on executive compensation paid by certain publicly held corporations.
The IRS issued proposed regulations that provide a safe harbor for corporations to calculate built-in gains and losses after an ownership change.
The end to hemp prohibition opens new industrial business opportunities for clients, making it important that CPAs have a working knowledge of industrial hemp.
Many taxpayers do not realize that the R&D tax credit is available to businesses of all sizes in many lines of business, not just major corporations conducting tests in research laboratories.
Sec. 302 affords a shareholder the advantage of sale or exchange (capital gain transaction) treatment on redeemed stock but only if the
redemption meets one of several tests.
LB&I recently announced it was adding six new
compliance campaigns to its list of areas on which to focus its examinations.
This discussion provides a high-level overview of the affiliated service group rules.
The IRS’s Large Business and International
Division released “Examining a Transaction
Costs Issue” regarding the treatment of transaction costs incurred in certain business transactions.
This discussion provides a summary of some of the basic previously taxed earnings and profits ordering rules likely to apply to distributions made by controlled foreign corporations .
This item summarizes the complexities of a digitalized economy for MNCs and considers the
multifaceted implications to U.S. MNCs with respect to financial statements and tax reporting.
The IRS announced that it is opening its Compliance Assurance Process (CAP) program to new applicants for the first time in years, but applications must be made between Sept. 16 and Oct. 31.
The IRS issued proposed regulations that provide a safe harbor for corporations to calculate built-in gains and losses after an ownership change.
Recently issued proposed regulations on the transfer of life insurance contracts create significant uncertainty regarding their application to tax-free asset acquisitions.
Now that NOL carryforwards are unlimited for tax years beginning after Dec. 31, 2017, practitioners
should be rethinking the use of the waiver of NOL carryforwards under Regs. Sec. 1.1502-32(b)(4) in acquisitions of a company with NOLs by a member of a consolidated group.
Under new Sec. 163(j), business interest expense deductions are limited, and a business interest expense that is disallowed in the current year is
carried forward to the succeeding tax year.
