Corporation income taxation

TOPICS / TAX

September 13, 2023

Guidance issued on applicability and calculation of new corporate AMT

In advance of proposed regulations, the IRS provided interim guidance to help corporations determine whether they are subject to the new corporate alternative minimum tax and how to calculate the tax, including how to determine financial statement income and applicable financial statement income.

August 7, 2023

Proposed regulations update, revise consolidated return regulations

New proposed regulations would update the regulations to reflect 50-plus years of statutory changes, remove regulations and certain transition rules that no longer have practical application, and eliminate obsolete or incorrect terms and cross-references.

August 1, 2023

Drug patent litigation expenditures are held deductible

The origin-of-the-claim test in Gilmore controls, the Court of Federal Claims concludes.

July 1, 2023

Bad debt deduction denied

An LLC’s cash advances to a corporation in which the LLC’s owners held shares represented equity, not bona fide debt, the Tax Court held.

June 8, 2023

Penalty for underpayment of estimated corporate AMT waived for 2023

The IRS waived the penalty for corporations that did not make estimated payments of corporate AMT for their 2023 tax year, saying the move is “in the interest of sound tax administration.”

May 2, 2023

Proposed regs. provide rules for repatriation of intangible property

The regulations would 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

April 13, 2023

IRS obsoletes 1958 revenue ruling on research and experimental costs

The ruling, which is being obsoleted as of July 31, allowed a taxpayer that used the expense method for research and experimental expenditures to deduct on an amended return research and experimental expenditures the taxpayer did not deduct in prior years.

April 11, 2023