The Tax Court held that a Texas rancher operated with a profit motive, despite “troublingly large” losses more than 77 times his gross receipts from farming and ranching.
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TOPICS / TAX
Corporation income taxation
IRS updates FAQs on business interest limitation, premium tax credit
The updates reflect changes made in H.R. 1, P.L. 119–21, commonly known as the One Big Beautiful Bill Act.
Managing MNE subsidiaries during tariff shocks
Multinational enterprises’ subsidiaries need other incentives to optimize their performance if transfer pricing policies guarantee them a routine profit.
Tax Court allows ordinary deduction of termination fees
Rights and obligations of an agreement pursuant to which the taxpayer paid a “break fee” terminating a proposed merger were in the nature of services, the court held, denying the IRS’s recharacterization of the fee under Sec. 1234A as a capital loss.
IRS withdraws prop. regs. affecting corporate spinoff transactions
The proposed regulations were withdrawn in response to comments that criticized the proposed guidance, according to the IRS.
Guidance on research or experimental expenditures under H.R. 1 issued
The revenue procedure advises taxpayers how to make various elections, file amended returns, and change accounting methods as provided under Section 70302 of the new law.
AICPA presses IRS for guidance on domestic research costs in OBBBA
In its letter, the AICPA said small businesses that have not filed returns for the 2024 filing period face uncertainty about how to treat domestic research and experimental expenditures.
IRS includes several AICPA recommendations in corporate AMT interim guidance
In a notice issued Tuesday, the IRS said it intends to partially withdraw proposed regulations and issue revised proposed regulations.
AICPA makes Priority Guidance Plan recommendations to IRS
In addition to its 183 recommendations for the IRS plan, the AICPA encouraged the agency to continue to pursue tax simplification.
Appeals court leaves tariffs in place, seeks expedited argument schedule
A federal appeals court extended its stay of a nationwide injunction on tariffs imposed by a trade court and proposed a schedule that would include oral arguments on July 31 in the challenge to the president’s authority.
Simplified method to determine corporate AMT applicable status issued
A notice issued by the IRS with interim guidance for the application of the corporate alternative minimum tax offers an optional simplified method for determining applicable corporation status under Sec. 59(k).
AICPA comments on proposed regs. on new transfer-pricing method
The comments are in response to Notice 2025-04, which announced plans for the simplified and streamlined approach as a new transfer-pricing method under Sec. 482 regulations for pricing of baseline marketing and distribution activities.
What happens next with the TCJA? Tax professionals are concerned
A Bloomberg Tax survey found that more than 4 in 5 respondents are moderately to very worried about the potential sunset of the Tax Cuts and Jobs Act, which expires at the end of 2025.
Transfer pricing: Not just for the tax department
Financial reporting needs to be given greater attention as the stakes of transfer pricing disputes rise.
Intangible property repatriation rules finalized
The regulations terminate the continued application of the Sec. 367(d) annual inclusion in certain cases when intangible property is repatriated to the United States after previously being transferred to a foreign corporation.
ERC supplemental claim process opened for third-party payroll companies
The IRS announced that it will open a supplemental claim process to help third-party payers and their clients resolve incorrect claims for the employee retention credit. The deadline is Nov. 22.
Corporate AMT proposed regulations issued; some penalties waived
The IRS issued proposed regulations providing guidance on the corporate alternative minimum tax (AMT) and a notice that waives the penalty for failure to pay estimated tax with respect to the corporate AMT for 2024.
Credit card reward liabilities may be eligible for recurring-item exception
The Office of Chief Counsel approves
accrual of liability, distinguishing the
situation in a CCA from that of Giant
Eagle, Inc.
FinCEN uses TV ad to tell businesses about BOI
The PSA uses a chat between friends in a coffee shop to educate small businesses about beneficial ownership information reporting, which 32.6 million businesses must file.
BOI requirements roll along despite concerns about too little outreach
FinCEN, which oversees beneficial ownership information reports, has received just 2.7 million of the 32.6 million reports that it expects. Through June, FinCEN said, it has reached more than 90,000 stakeholders.
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