Bifurcation is delayed indefinitely, some entities are excepted, and the effective dates are delayed.
C Corporation Income Taxation
Income from forfeited deposits of terminated contracts related to Sec. 1231 property is not eligible for capital gain treatment under Sec. 1234A.
The new rules are part of the Treasury Department’s larger effort to curb corporate inversions.
The Third Circuit reverses the Tax Court on accrual-basis retailer's customer reward program.
The IRS issued regulations restricting the ability of C corporations to use this method.
These new rules aim to curtail an inverted company’s ability to access foreign subsidiaries’ earnings without paying U.S. tax.
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.
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.
Multinational corporations may face high levels of tax on effectively connected income.
The Consolidated Appropriations Act introduced in Congress on Wednesday would extend a large number of expired tax provisions.
the IRS announced additional rules designed to curtail the ability of an inverted company to access foreign subsidiaries’ earnings without paying U.S. tax.
Purported DISC commissions paid to Roth IRAs as owners of a holding company are recharacterized as dividends to shareholders and excess contributions.
Ninth Circuit remands a case for analysis of a stock sale's economic substance.
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.
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.
FASB proposed two standards changes that are designed to reduce complexity in accounting for income taxes.
The surviving corporation and acquired corporations in a merger are considered the same taxpayer for purposes of interest offsetting.
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.
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.