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.
Tax Planning; Tax Minimization
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).
Practical ways to enhance operational transfer-pricing processes
For companies that engage in intercompany transactions, being proactive in preparing for disruptions and regulatory changes is essential.
ESG and taxation: A necessary part of a company’s strategic objectives
Businesses are likely to find themselves at a competitive disadvantage if they don’t keep abreast of tax aspects of ESG.
Paying dividends as a tax planning strategy
Determining the best way to extract cash from a corporation depends on many factors and assumptions; here is how to evaluate paying compensation vs. dividends.
Considerations for multinationals with US and Maltese operations
This discussion explores certain issues that multinationals should consider when deciding whether to use Malta as part of their worldwide operations.
Foreign-derived intangible income: Issues and practical strategies
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.
Acceleration of deferred revenue in M&As
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.
Accounting method planning to decrease taxable income
This item provides examples of accounting method changes or elections that may decrease taxable income.
Critical valuation issues that arise in common corporate transactions
This discussion provides an overview of some of the critical valuation issues that arise in Secs. 351, 332, and 338.
Accounting method planning to increase taxable income
In certain circumstances, taxpayers may benefit from increasing taxable income; accounting method planning can help taxpayers achieve that objective.
Practical considerations of Sec. 1202 in M&A transactions
This article provides an overview of the Sec. 1202 requirements and discusses the practical considerations of the provision in merger-and-acquisition transactions.
A walk through the step-transaction doctrine
This article discusses the step-transaction doctrine, the three tests used to determine if it applies, and advice for taxpayers to help avoid an IRS challenge of the tax treatment of a series of transactions based on the doctrine.
Debt workouts involving commercial real estate
As short-term agreements that borrowers and creditors reached at the beginning of the pandemic start to expire, real estate companies and others will need to find long-term solutions to their insolvency problem.
Choosing a tax year for a personal service corporation
A personal service corporation must generally use a calendar year, but it can choose a fiscal year in certain circumstances.
Tax-saving opportunities for the housing and construction industries
This item discusses how businesses can qualify for incentives in the housing and construction industries and how tax preparers can assist them in claiming these tax benefits.
