Ideas & Insights

New final regulations include rules for CFCs, depreciation/amortization ‘add-back recapture’ and self-charged interest.

For corporations with NOLs that anticipate 2021 income, a change of fiscal year may mitigate the impact of the 80% NOL deduction limitation.

The IRS released final regulations affecting S corporations that revoked their status in response to TCJA and lower C corporation tax rates.

The IRS clarifies overpayment claims for tax attributes created or released by carrying back an NOL enjoy an extended limitation period.

Final regulations allow any reasonable method to be applied in calculating deduction amounts allowed under sections 250, 172, and 163(j).

Provides more time to elect out of 163(j) interest deduction limitation for taxpayers with certain real property or farming businesses.

CARES Act provides general increase to the limitation amount (i.e., the maximum allowable deduction) and special rule for partnerships

Coronavirus Aid, Relief and Economic Security Act provides liquidity by providing five-year NOL carryback and other help for corporations.

The comment letter explains that certain S corporations that experienced an ownership change should also qualify under these rules.

Notwithstanding unfavorable changes to the Code, capital gain treatment is still available on the sale of patents in certain scenarios.

Final regulations affect whether a controlled foreign corporation is a related person under attribution rules.

Comments address concerns and recommendations regarding proposed regulations addressing section 382 built-in gains and losses.

Favorable rule for corporate stock acquisitions where life insurance contracts are less than 50 percent of the target corporation’s assets.

New IRS enforcement campaign targeting the section 965 transition tax compliance indicates a likely increase in section 965 audit activity.

The IRS released long-awaited guidance outlining how former S corporations should source distributions between S corp and C corp earnings.

IRS to retain regulations treating some related party debt as equity, but will propose rules easing one of the regulations’ harshest rules.

A business guide to tax considerations for 2019 to help make informed decisions after the Tax Cuts and Jobs Act.

A federal district court agreed with the IRS that an S corporation’s AAA balance resets to zero following a switch to C corporation status.

Final bonus depreciation rules similar to previously proposed rules, uncertainty remains for certain transactions.

Tax Court allows ordinary business bad debt deduction, rejecting argument that loans not secured by real property were nonbusiness loans.