Tax practitioners are seeing a rise in IRS audits directed at companies using captive insurance arrangements (captives).
Oil and gas companies need to be prepared for several provisions of PPACA that go into effect in 2014; the nature of the industry raises some special concerns for oil and gas employers.
The IRS issued final regulations that provide guidance on the recognition of built-in gain in certain transfers of property from a C corporation to a RIC or REIT.
The oil and gas industry faces numerous challenges in applying the fact-intensive rules of the so-called repair regulations to costs incurred to repair and maintain property during its service life.
Once every five years an insurer has an opportunity to elect to use its own payment pattern to discount losses (loss reserves and loss adjustment expenses) for tax purposes.
In CCA 201235010, the IRS determined that the intangible drilling cost preference exception may not be used in tax years when the taxpayer has negative alternative minimum taxable income.
The IRS issued an Industry Director Directive addressing partial worthlessness deductions under Sec. 166(a)(2) taken by insurance companies for eligible loans.
The severe drought experienced by much of the United States this year, especially in agricultural regions, is expected to produce a record number of crop insurance claims.
Taxpayers in the construction industry may want to consider the Sec. 41 research credit.
In light of the lack of guidance on whether the new codified economic-substance rules apply to captive insurance companies, it is prudent to assume that the law does apply.
The Capital Construction Funds program encourages construction, reconstruction, or acquisition of vessels by allowing owners or operators to defer federal income taxes under Sec. 7518 on certain money or other property placed into a CCF.
Governments sometimes make payments to telecommunications carriers for providing telephone and communication services to low-income users and those in remote or isolated areas. The courts have recently addressed the tax treatment of those payments.
A recent IRS letter ruling provides helpful insights to independent producers of oil and gas that, by claiming allowable percentage depletion deductions, can lower their costs, while at the same time securing contracts for bulk sales of oil and gas with industrial, commercial, and government entities.
In a private letter ruling, the IRS’ Office of Chief Counsel allowed a private bank catering to high-wealth individuals to deduct as ordinary and necessary trade or business expenses the payments it made to settle lawsuits arising from criminally fraudulent activities by one of the bank’s fund managers.
This item provides an overview of the Section 1603 renewable energy grant program, which was extended for one year by the Tax Relief, Unemployment Insurance Reauthorization, and Job Creation Act of 2010.
This item reviews the Capital Construction Fund (CCF) program, which allows owners and operators of U.S. flag vessels to accumulate the large amounts of capital by deferring federal income taxes on certain deposits of money or other property placed into the fund.
Proposed regulations put intercompany insurance transactions between members of a consolidated group on the self-insurance method of accounting.
Editor: Joel E. Ackerman, CPA, MST The IRS ruled in Rev. Rul. 2007-47 that payments to an insurance company to cover future capped costs were not insurance payments for tax purposes. The "premium" was an amount equal to the present value of estimated future remediation costs required by the government.
Editor: Annette B. Smith, CPA Historically, a mutual fund seeking to maintain status as a regulated investment company (RIC) has had limited economic exposure to commodity prices. For example, neither commodity futures contracts nor direct purchases or sales of commodities generate RIC qualifying income under Sec. 851(b)(2). Recently, Rev. Rul.
Executive Summary Premiums from a service-warranty contract can be taken into account in four different ways: full inclusion; service-warranty accounting; advance payments; or as an insurance company. Under the first three methods, the warranty provider is not subject to mandatory C corporation status; however, the insurance company route offers the