Federal Tax Forum

Join RSM for six federal tax sessions!

This multisession forum takes a deeper look at federal tax issues and trends.

Updates to IRS operational status and enforcement priorities

The IRS issued an ambitious operating plan that includes objectives to improve customer service, resolve taxpayer issues, expand enforcement activities, deliver cutting-edge technology and increase IRS staff. Over half of the $80 billion in IRS' additional funding is allocated to enforcement. In this presentation, panelists will discuss enforcement trends, how the IRS selects cases for examination and how to prepare for an IRS exam. 

Presenters:

• Lia Colbert, SB/SE Commissioner, Internal Revenue Service
• Alina Solodchikova, Principal, RSM US LLP
• Holly Paz, Commissioner of the Large Business & International Division of the IRS

What’s new on Capitol Hill

This discussion highlights areas of tax legislative focus for the remainder of 2023 and 2024, encompassing topics such as (i) possible changes to expensing of research and experimentation costs, interest deduction rules for businesses and the rules governing bonus depreciation; (ii) a look at areas of increased IRS focus with its new funding under the Inflation Reduction Act; and (iii) a preview of the potential tax policy landscape in 2025 and beyond given the expiration of many provisions of the Tax Cuts and Jobs Act at the end of 2025, as well as the implementation of OECD Pillar 2 by a number of countries around the world.

Presenters: 

• James Alex, Principal, RSM US LLP
• David Kautter, Partner, RSM US LLP
• Matt Talcoff, Partner, RSM US LLP

Tax accounting considerations for recent legislative and global developments

In this session, we will cover various tax law and regulation changes that could have an impact on accounting for income taxes for financial reporting.

Presenters: 

• Al Cappelloni, Partner, US LLP
• Darian Harnish, Senior Manager, RSM US LLP

Recent trends in M&A deals

Regardless of the pace of deal flow, businesses involved in transactions will benefit from this session, where we will share the following: 

1. Considerations in structuring to achieve section 1202 qualified small business stock. 
2. Should buyers and sellers agree on a purchase price allocation?  
3. How valuable are the tax attributes I am buying or selling?  
4. Can make-whole provisions be used to mitigate risk in deals?   

Presenters: 

• Stefan Gottschalk, Managing Director, RSM US LLP 
• Patrick Philips, Principal, RSM US LLP 

Traps for the unwary in monetizing Inflation Reduction Act credits

Now that taxpayers have been generating energy credits under the IRA, taxpayers are looking for ways to monetize the generated credits. While the IRS has released guidance, plenty of challenges could jeopardize maximizing the benefit of the credits. We will look at the guidance, an overview of the market to date, and hurdles to surmount when selling or purchasing IRA credits. 

Presenters: 

• Debbie Gordon, Principal, RSM US LLP 
• Dana Jackson, Partner, RSM US LLP
• Christian Wood, Principal, RSM US LLP

The latest on Section 174: What you need to know now

The panel will discuss IRS Notice 2023-63, the first item of substantive guidance issued by the IRS in response to the new rules under section 174 requiring capitalization and amortization of research & experimental expenditures. The Notice provides guidance taxpayers can rely on in anticipation of proposed regulations and details several areas where the IRS is seeking comments. During this session, we’ll cover issues including the types of costs the Notice includes as R&E expenditures, interplay with the section 41 research and development tax credit, treatment of unamortized costs after certain transactions, and considerations for taxpayers that filed their 2022 tax returns applying methodologies that may be inconsistent with the Notice.

Presenters:

• Kate Abdoo, Principal, RSM US LLP
• Fred Gordon, Managing Director, RSM US LLP
• Nick Gruidl, Partner, RSM US LLP
• David Hudson, Senior Director, RSM US LLP