The Tax Court affirmed bargain sale treatment for a transfer of for-profit colleges to a nonprofit entity but adjusted the taxpayer’s claimed charitable deduction for the transfer.
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S Corporation Income Taxation
Nondeductible W-2 wages not included in Sec. 199A deduction computation
The Tax Court determined that W-2 wages that are not deductible under Sec. 280E in calculating taxable income are not included when calculating the Sec. 199A qualified business income (QBI) deduction.
PTEs need more notice of changes, more time to respond, AICPA says
In a letter to Treasury and the IRS, the AICPA seeks changes to tax reporting requirements for partnerships and S corporations.
Flowthrough forfeiture loss deduction denied
Application of the public policy doctrine is not limited to where a criminally convicted person directly pays a fine or penalty, the Tax Court held.
IRS withdraws prop. regs. affecting corporate spinoff transactions
The proposed regulations were withdrawn in response to comments that criticized the proposed guidance, according to the IRS.
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.
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).
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.
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.
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.
Updated FAQs provide details on phase-in timing of BOI access
The FAQs from Treasury’s Financial Crimes Enforcement Network said access to beneficial ownership information will be phased in, beginning this spring with a pilot program for some federal agency users and concluding in spring 2025, when financial institutions with customer due-diligence requirements will be able to review BOI.
Proposed regs. issued for 1% excise tax on corporate stock repurchases
Two sets of proposed regulations issued by the IRS provide guidance on the implementation of the new excise tax and on rules for the procedure and administration applicable to the reporting and payment of the tax.
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