The IRS’s release of Notice 2021-49 provides employers with additional guidance on issues of the employee retention credit.
C Corporation Income Taxation
Final regulations clarify the treatment of qualified improvement property in FDII and GILTI, and foreign tax credit transition rules address post-2017 NOL carrybacks to pre-2018 tax years.
The proposal would raise tax rates for corporations and individuals and make many other changes to the Internal Revenue Code.
The tax impact on future shareholder distributions should be considered prior to liquidating an acquired subsidiary.
The IRS has posted two sets of FAQs that explain changes to the child and dependent care credit and to the sick and family leave credits made by the American Rescue Plan Act.
This item summarizes the traditional Up-C/TRA arrangement and addresses the impact of Sec. 280E on the Up-C/TRA structure.
Global supply chain problems caused by the COVID-19 pandemic have made it difficult for US companies to replace inventories, potentially subjecting them to additional taxable income. The AICPA has requested relief under Sec. 473.
Certain employers have until Nov. 8 to submit a required worker certification request to a designated local agency for purposes of the work opportunity credit.
Under the safe harbor, an employer can exclude certain amounts received from other coronavirus economic relief programs in determining whether it qualifies for the employee retention credit based on a decline in gross receipts.
New guidance clarifies the application of the credit to “recovery startup businesses” and the treatment of wages paid to majority owners and their spouses.
This article discusses issues that have evolved around FDII where there has been little guidance and outlines ways to better take advantage of the FDII regime.
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.
Recently released IRS Chief Counsel Advice targeted at the BTC/BCH hard fork also provides insight into how the IRS may evaluate more complex cryptoasset transactions.
The proposed $6 trillion fiscal year 2022 budget unveiled by the Biden Administration includes a host of tax items, including proposals to raise the corporate tax rate, raise the top tax rate for high-income individuals, limit like-kind exchanges, and make permanent recent temporary changes to various tax credits.
As SPAC activity has increased, non-U.S.-domiciled SPACs have become more prevalent and carry major U.S. tax-compliance ramifications due to their potential treatment as a PFIC for U.S. investors.
Sec. 199A, may create a potential difference in how the same type of income is taxed to shareholders of RICs and REITs and therefore offers an opportunity for fund managers.
This discussion provides an overview of some of the critical valuation issues that arise in Secs. 351, 332, and 338.
Sec. 451(c) should be considered when structuring such M&A transactions — including special rules relating to short tax years of 92 days or less.
Treasury takes a more aggressive stance on reporting of virtual currency transactions.
Various options are available for mitigating penalties for noncompliance with foreign return filing requirements.