The American Taxpayer Relief Act of 2012, P.L. 112-240, extended the research and development (R&D) credit under Sec. 41 for two years to cover qualified research expenditures paid or incurred on or before Dec. 31, 2013. Though U.S. business taxpayers welcomed the extension of this tax credit, the benefit is
Business tax
Final regulations for Sec. 336(e) elections are issued
On Monday, the IRS issued final regulations on the rules that apply when an election under Sec. 336(e) is made to treat the sale, exchange, or distribution of at least 80% of the voting power and value of a corporation’s stock (target) as a sale of all its underlying assets,
Final rules require EIN updates
On Friday, the IRS issued final regulations requiring taxpayers that obtain employer identification numbers (EINs) to update their information with the IRS (T.D. 9617). The regulations, which will apply beginning Jan. 1, 2014, to give the IRS time to publish the relevant form and instructions, adopt without change proposed regulations
Dow SLIPs in court
The U.S. District Court for the Middle District of Louisiana disallowed deductions generated by two Special Limited Investment Partnerships (SLIPs) transactions because the transactions lacked economic substance and did not have a nontax business purpose. In addition, the court found that the two partnerships at the heart of the transactions
Qualified small business stock
For taxpayers other than corporations, Sec. 1202 excludes from gross income at least 50% of the gain recognized on the sale or exchange of qualified small business stock (QSBS) that is held more than five years. For qualifying stock acquired after Feb. 17, 2009, and on or before Sept. 27,
Long-awaited final regs. issued on noncompensatory partnership options
The IRS issued regulations (T.D. 9612) finalizing proposed regulations (REG-103580-02), which were issued in January 2003, on the treatment of certain call options, warrants, convertible debt, and convertible equity that are not issued in connection with the performance of services, i.e., noncompensatory partnership options. The final regulations apply to noncompensatory
A conversation about tax reform
Sponsored by Drake Software As Congress took steps earlier this year to enact the first major tax reform since 1986, the JofA turned to three leaders in tax policy for their thoughts on the directions, goals, and prospects for reform. Two of them participated as tax counsel staff to congressional
AICPA makes tax reform recommendations to Ways and Means Committee working groups
In response to concerns that “[t]he proliferation of new income tax provisions since the 1986 tax reform effort has led to complex compliance hurdles for taxpayers, administrative complexity and enforcement challenges for the Internal Revenue Service,” the AICPA submitted recommendations for tax reform to five of the 11 working groups
Basis reporting for debt instruments and options is phased-in
In final regulations implementing the basis reporting requirements under Sec. 6045(g) that apply to debt instruments and options, the IRS, in response to comments about the complexity of complying with these rules, is implementing the reporting requirements for debt instruments and transfer reporting in phases, to give brokers ample time
President proposes many tax changes in 2014 budget
President Barack Obama released his proposed FY 2014 budget on Wednesday. In it, he aims to raise approximately $580 billion in revenue through new taxes, limits on deductions, and other tax proposals. The revenue-raising portion of the proposed budget generally mirrors the president’s proposals made during the fiscal cliff negotiations
Proposed regs. would govern employment tax liability of third-party agents
The IRS released proposed regulations (REG-102966-10) under Sec. 3504 (acts to be performed by agents) that would govern the liability for employment taxes when an employer designates an agent under a “service agreement” to pay its employees and to satisfy all employment tax obligations. Such agents include payroll service providers,
Simplified home office deduction safe harbor now available
In Rev. Proc. 2013-13, issued in January, the IRS gave taxpayers an optional safe-harbor method to calculate a deduction for expenses of a business use of a residence under Sec. 280A, effective for tax years beginning in 2013. Individual taxpayers who elect this method can determine the deduction by multiplying
IRS extends suspension of examinations of tangible property capitalization issues
On Wednesday, the IRS posted an updated Large Business & Industry (LB&I) Directive for field examinations on the repair vs. capitalization issue that extends the suspension of examinations (LB&I-04-0313-001). The effective date of the tangible property temporary regulations (T.D. 9564) (in amendments published Dec. 17, 2012) has been extended to
Tax filing resources—Tax year 2012
This is the one-stop shop for all the updates you need to know for this year’s tax filing season. Find resources from the Journal of Accountancy, plus tax return checklists and tax savings tips from the AICPA, categorized by tax topic. INDIVIDUAL TAX All 2012 tax returns can now be
Tax reform prospects good, say veterans of 1986 reform
Developments since the 1986 Tax Reform Act was signed favor a successful outcome for the current reform effort, said two experts who worked for congressional committees producing the earlier legislation. But they also agreed that a tax reform bill probably won’t be enacted until next year. Don Longano and Mel
Regs. issued on asset transfers to foreign corporations
The IRS on Monday issued final, temporary, and proposed regulations governing outbound asset transfers under Sec. 361. T.D. 9614 contains final regulations that apply to transfers of certain property (including stock and securities) by a domestic corporation to a foreign corporation in certain nonrecognition exchanges and to distributions of stock
Employers have additional time to claim work opportunity tax credit
On Friday, the IRS announced that it was extending the time employers who want to claim the work opportunity tax credit (WOTC) have to file Form 8850, Pre-Screening Notice and Certification Request for the Work Opportunity Credit (Notice 2013-14). Form 8850 is usually due no later than 28 days after
Sequestration will lead to IRS cuts in services, enforcement, and tax-related payments
Now that sequestration has taken effect, the IRS has announced the following reductions in tax-related payments as a result of the Budget Control Act of 2011, P.L. 112-25. These reductions are effective beginning on March 1, 2013, until either the end of the government’s fiscal year (Sept. 30, 2013) or
The benefits of captive insurance companies
For many years, large corporations in this country have enjoyed many benefits from operating their own captive insurance companies. Most were established to provide coverage where insurance was unavailable or unreasonably priced. These insurance subsidiaries or affiliates were often domiciled offshore, especially in Bermuda or the Cayman Islands. The risk
Voluntary Classification Settlement Program expanded
The IRS significantly modified its Voluntary Classification Settlement Program (VCSP). In Announcement 2012-46, in effect until June 30, 2013, the IRS is temporarily permitting employers who have not filed Forms 1099 for their workers to participate in the program by paying a larger amount of past-due tax than under the
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Preparing clients for new provisions next tax season
As the 2025 filing season approaches, H.R. 1 introduces significant tax reforms that CPAs must be prepared to navigate. These legislative changes represent some of the most comprehensive tax updates in recent years, affecting both individual and corporate taxpayers. This report provides in-depth analysis and guidance on H.R. 1.
