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.
Tax Planning; Tax Minimization
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.
