Corporation income taxation
Partnerships and S corps. can deduct state and local taxes
The IRS said it would issue proposed regulations allowing S corporations and partnerships to deduct “specified income tax payments” paid to state and local governments above the line and not as passthrough items for partners and shareholders.
Deducting losses in the CARES Act’s window
For a limited time, taxpayers have flexibility for using net operating losses.N.J. business incentive grants are taxable
The Third Circuit reverses the Tax Court, which had held the relocation payments to be nonshareholder capital contributions.Consolidated group NOL rules are finalized
The IRS finalized regulations governing the treatment of net operating losses by consolidated groups after recent legislation changed the rules.Several states provide one-month filing relief for corporate deadlines
With the Oct. 15 corporate tax filing deadline looming and the global pandemic still affecting taxpayers and practitioners, several states have provided one-month filing relief for their corporate Oct. 15 deadlines.IRS releases final rules on business meals and entertainment
The IRS finalized rules implementing provisions of the law known as the Tax Cuts and Jobs Act, P.L. 115-97, disallowing deductions for most business entertainment expenses and distinguishing them from business food and beverage expenses that remain deductible.Settlement agreement’s capital gain allocation withstands challenge by IRS
The Tax Court finds a payment was for repudiated joint venture interests, not future income.Final regs. govern eligible terminated S corporation rules
The IRS finalized proposed regulations on eligible terminated S corporations, a new provision enacted under the Tax Cuts and Jobs Act that provided favorable treatment for corporations that wished to terminate their S elections.Regulations coming on S corporations with accumulated E&P and GILTI
The IRS announced that it will issue regulations to allow S corporations with accumulated earnings and profits to elect to have global intangible low-taxed income inclusions increase the S corporation’s accumulated adjustments account.GILTI rules address income subject to high foreign tax rate
The IRS issued final regulations under the global intangible low-taxed income (GILTI) rules on the treatment of income subject to a high rate of foreign tax. At the same time, the IRS issued proposed rules conforming the GILTI high-tax exception rules with the Subpart F high-tax exception.Consolidated groups get NOL guidance
The IRS issued proposed and temporary regulations explaining how consolidated groups should apply the changes to the net operating loss rules enacted by the CARES Act.Proposed regs. explain disallowed transportation fringe benefits
The IRS issued proposed regulations implementing changes to Sec. 274 that disallow a deduction for the expense of any Sec. 132(f) qualified transportation fringe provided to an employee, effective for amounts paid or incurred after Dec. 31, 2017.Leave-based donation program available during pandemic
The IRS announced that employers may make donations this year to charitable organizations that provide relief to COVID-19 pandemic victims in exchange for personal leave that their employees forgo.Chartering vessel to decommission oil and gas wells is ECI
Continental shelf activities are nonexempt under the US—UK treaty, the Tax Court holds.Final regs. clarify when interest in corporation is stock vs. debt
The IRS has issued final regulations addressing when certain related-party interests in corporations should be treated as stock vs. debt.AICPA challenging nondeductibility of PPP-related expenses
The IRS issued guidance clarifying that a deduction is disallowed for expenses for payroll costs, mortgage interest, rent, utilities, and other interest on debt obligations to the extent they are being reimbursed by loans forgiven under the Paycheck Protection Program.Quick relief with the CARES Act
Chris Hesse, CPA, the AICPA Tax Executive Committee chair, analyzes how the CARES Act’s provisions allowing carryback of net operating losses for 2018 through 2020 interact with other new provisions.
