Corporation income taxation

TOPICS / TAX

October 14, 2016

Earnings-stripping rules make many changes from proposed regs.

The new rules are part of the Treasury Department’s larger effort to curb corporate inversions.

October 1, 2016

Deduction allowed for unredeemed ‘fuelperks!’

The Third Circuit reverses the Tax Court on accrual-basis retailer’s customer reward program.

June 7, 2016

Tax-free REIT spinoffs are curtailed

The IRS issued regulations restricting the ability of C corporations to use this method.

April 5, 2016

IRS’s inversion rules include earnings-stripping provisions

These new rules aim to curtail an inverted company’s ability to access foreign subsidiaries’ earnings without paying U.S. tax.

February 9, 2016

President’s budget proposes many tax changes

In addition to a proposed spending blueprint for the government, President Barack Obama’s proposed FY 2017 federal budget contains a wide variety of tax law changes that would affect individuals and businesses.

February 1, 2016

Profit shifting: Effectively connected income and financial statement risks

Multinational corporations may face high levels of tax on effectively connected income.

February 1, 2016

Overview of the ECI rules

This sidebar provides a brief explanation of the Internal Revenue Code’s effectively connected income (ECI) rules that may impose direct U.S. tax on certain income earned by any foreign corporation.

December 16, 2015

Tax extender legislation introduced in Congress

The Consolidated Appropriations Act introduced in Congress on Wednesday would extend a large number of expired tax provisions.

November 20, 2015

New corporate anti-inversion rules issued

the IRS announced additional rules designed to curtail the ability of an inverted company to access foreign subsidiaries’ earnings without paying U.S. tax.

October 1, 2015

Substance-over-form doctrine used to nix growth within Roth IRAs

Purported DISC commissions paid to Roth IRAs as owners of a holding company are recharacterized as dividends to shareholders and excess contributions.

September 1, 2015

Tax Court to reconsider its previous denial of stockholders’ transferee liability

Ninth Circuit remands a case for analysis of a stock sale’s economic substance.

July 28, 2015

Tax Court invalidates stock-based compensation rule in cost-sharing agreements

The Tax Court held that Regs. Sec. 1.482-7(d)(2), requiring entities to share stock-based compensation costs under qualified cost-sharing agreements, failed to meet the reasoned decision-making standard and was invalid.

April 13, 2015

Tax practice responsibilities involved in Schedule UTP

The need to file Schedule UTP, Uncertain Tax Position Statement, may have taken many corporate taxpayers by surprise in 2014, since the asset threshold for compliance was lowered from $50 million to $10 million.

February 2, 2015

FASB proposes two changes to simplify accounting for income taxes

FASB proposed two standards changes that are designed to reduce complexity in accounting for income taxes.

February 1, 2015

Merged corporations can offset tax interest

The surviving corporation and acquired corporations in a merger are considered the same taxpayer for purposes of interest offsetting.

December 24, 2014

Regulations tightening Form 5472 filing requirements are finalized

The IRS finalized proposed regulations issued last June requiring corporations to file Form 5472 with their timely filed tax returns or pay a large penalty.

December 1, 2014

IRS puts would-be corporate inverters on notice

Coming regulations will reduce tax benefits of inversions by preventing certain uses of controlled foreign corporations and closing loopholes in the Sec. 7874 anti-inversion provisions.

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