1. TAX

Corporation income taxation

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.
IMAGE BY CUTIMAGE/ADOBE STOCK

Transfer pricing: Not just for the tax department

Financial reporting needs to be given greater attention as the stakes of transfer pricing disputes rise.

Equitable and collateral estoppel fail to shield S corporation distribution

Divorce, bankruptcy, and death ultimately result in taxable S corporation distribution for surviving shareholder.

Disproportionate distributions did not terminate corporation’s S status

Shareholders’ “looting” of the company did not create a second class of stock, the Tax Court held.

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.

FinCEN estimates millions of hours will be spent seeking BOI access

Almost 16,000 entities will spend over 8.7 million hours seeking access to beneficial ownership information in the first year, FinCEN estimated in a new notice.

Final regs. issued for 1% excise tax on corporate stock repurchases

The final regulations provide guidance regarding the reporting and payment of the excise tax on repurchases of corporate stock made after Dec. 31, 2022.

Tax Court reverses course on conservation easement extinguishment regs.

The regulations are procedurally invalid; the donor’s deed satisfied the statutory requirements, the court holds.
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