Ideas & Insights

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

Revenue procedure allows treatment of qualified residential living facility operations as a section 163(j) real property trade or business.

The final regulations implement the amendments made to section 162(m) by the TCJA and largely mirror last year’s proposed regulations.

German tax may apply to payments for the licensing or sale of German registered IP, even if neither party resides in Germany.

China has dominated global supply chains, but with rising labor costs, a U.S.-China trade war and the COVID-19 outbreak, this may change.

In line with decades of case law and rulings, IRS ruling looks to benefits and burdens of ownership to determine tax ownership.

Section 1202 could provide small business investors with a complete exemption of gain realized from the sale of QSB stock.

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 announced that December 31, 2020 will be the last date to submit tentative net operating loss carryback claims via fax.

IRS has issued two campaigns for Life Insurers and issues regulations on the calculation of life insurance reserves under section 807(d).

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

The United States’ fiscal response to the pandemic and the upcoming federal election signal tax rate increases and a need for planning.

Recent memo provides IRS view that certain stockless contributions create a split holding period on the stock.

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).

Changes to NOL rules under the TCJA and CARES Act are implemented for consolidated corporate groups under new proposed regulations.

Temporary regulations provide election filing procedures to implement retention of NOL tax benefits by acquiring consolidated group.

Retroactive law changes found in the CARES Act raise questions on the proper timing for adjusting corporate E&P.

Questions and answers about how NOL carryback refund claims should address AMT calculations are now available on the IRS’ website.

Many companies miscalculate the available accelerated depreciation on qualified leasehold improvements. Is your company one of them?