Tax Accounting (Methods & Periods)

Review of FIN 48 isn’t necessary, FASB decides

FASB has concluded that it is not necessary to review or reconsider FIN 48 as a result of a “post-implementation review” conducted by FASB’s parent organization, the Financial Accounting Foundation (FAF). The FAF review found that FASB Interpretation No. 48, Accounting for Uncertainty in Income Taxes (FIN 48), is resulting

IRS suspends repair/capitalization exams pending accounting method changes

On Thursday, the IRS issued a Large Business & Industry (LB&I) Directive for field examinations on the repair vs. capitalization issue that essentially suspended current examinations so as to permit taxpayers to file accounting method changes under just-issued revenue procedures (LB&I-4-0312-004). Taxpayers that are subject to the new temporary regulations

Much-anticipated guidance issued on accounting method changes for repair regs.

In December 2011, the IRS issued long-awaited temporary regulations on the treatment of tangible property repairs. On Wednesday, it issued two revenue procedures detailing how taxpayers may obtain IRS automatic consent to the accounting method changes required by the rules. Rev. Proc. 2012-19 addresses repair and maintenance, materials and supplies,

Disallowed deduction equals change in accounting method

The Fifth Circuit Court of Appeals upheld a Tax Court decision that a change in accounting method occurred when the IRS disallowed an accrual-basis taxpayer’s deduction for inventory purchased on account from a related-party cash-basis taxpayer. Therefore, the taxpayer was required to include amounts erroneously deducted in closed tax years

Act Public Before Going Public

After several years of increasing numbers of U.S. companies making initial public stock offerings, starting in late summer 2011, some companies postponed going public as economic and market conditions grew turbulent and uncertain. But even a holding pattern might have some advantages if companies use that time to better prepare

Final Regulations Simplify Accounting Rules in Corporate Reorganizations

The IRS issued final regulations (TD 9534) intended to clarify and simplify rules concerning continuity of accounting methods and inventory methods in certain tax-free corporate reorganizations and liquidations. The regulations revise regulations under IRC §§ 381(c)(4) and 381(c)(5) and adopt with nonsubstantive modifications proposed regulations issued in 2007 (REG-151884-03). They

Act 2 for Business Tax Incentives

Enacted in the waning days of the 111th Congress, the Tax Relief, Unemployment Insurance Reauthorization, and Job Creation Act of 2010 (2010 Tax Relief Act, PL 111-312) was a creature of political compromise. But the act nonetheless built upon already attractive incentives that had been passed only a few months

How the IRS Examines Repair and Maintenance Costs

Taxpayers are generally allowed to deduct the cost of making incidental repairs to their property used in carrying on any trade or business under IRC § 162 and Treas. Reg. § 1.162-4. However, to be deductible currently, a repair cost must not be subject to capitalization under IRC § 263(a).

Audit Guide Covers Capitalization Rules

Practitioners have been making use of a resource arising from the IRS’ ongoing audit initiative concerning capitalization rules. The IRS issued Capitalization v. Repairs Audit Technique Guide (LB&I-4-0910-023) as a framework for examining agents to follow when determining whether a business’s expenses should be capitalized or an immediate deduction allowed,

Automatic Procedures for Changing Accounting Methods Updated, Expanded

The IRS on Monday released updated procedures under which taxpayers can receive automatic consent to change their accounting methods (Revenue Procedure 2011-14). The revenue procedure updates prior guidance contained in Revenue Procedures 2008-52 and 2009-39 and gives additional accounting method changes for which taxpayers can obtain automatic consent. The revenue

IRS Updates Guidance on Adequate Disclosure of Positions

The IRS has released updated guidance identifying when a taxpayer’s disclosure of an item or position in an income tax return is adequate for purposes of reducing the understatement of tax penalty and the tax return preparer penalty for understatement due to unreasonable positions (Revenue Procedure 2011-13). The IRS regularly

IASB Proposes Amendment to Aspect of Deferred Tax Accounting

The International Accounting Standards Board (IASB) on Friday published for public comment an exposure draft, Deferred Tax: Recovery of Underlying Assets, that would amend one aspect of IAS 12, Income Taxes. The IASB said it is setting an exposure period of 60 days—shorter than its normal 120 days—because the amendments

The Proper Timing of Workers' Compensation Deductions

For companies with more than a de minimis amount in their workers’ compensation reserve, it may be worthwhile to review the details underlying the reserve amount. The reason? These days a significant portion of a workers’ compensation reserve likely results from amounts due to medical service providers for treatment already

New Accounting Methods Subject to Automatic Change Procedures

The IRS has issued new guidance on automatic accounting method changes. Revenue Procedure 2009-39 provides certain additions, modifications and clarifications to Revenue Procedures 2008-52 and 97-27 (as modified, amplified and clarified by various other revenue procedures). Revenue Procedure 2008-52 provides procedures for taxpayers to obtain automatic consent for certain changes

Credit Card Fees Are OID

The Tax Court held that credit card “interchange” fees received by subsidiaries of credit card issuer Capital One resembled interest that increased or created original issue discount (OID) related to the company’s pool of credit card receivables. As OID, a daily amount was properly included in income over the life

IRS Modifies Automatic Accounting Method Change Procedures

The IRS on Thursday modified the procedures for obtaining automatic consent to change an accounting method. Revenue Procedure 2009-39 amplifies, modifies and clarifies various earlier pieces of guidance that had established the general procedures for taxpayers to secure advance IRS consent to an accounting method change. Last year, the IRS

Executive Compensation: What's Reasonable?

When a corporate client seeks words of wisdom regarding tax planning, most CPAs go through the litany of suggestions related to acceleration of deductions and deferral of income. Yet one of the biggest and potentially most dangerous tax issues facing corporations is the compensation paid to the top executives and

Casting Doubt on the Accrual of Interest

Due to the recent turmoil in the credit markets, creditors and borrowers alike are evaluating the tax treatment of interest accruals related to troubled loans. Generally under Treas. Reg. § 1.446-2(a), interest is taken into account by a taxpayer according to the taxpayer’s regular method of accounting. Beyond the specific

Erroneous LIFO Methodology

A mistake made in a taxpayer’s last-in, first-out (LIFO) computation may repeat in later-year returns if staff preparing the computation take a “same as last year” approach. When the mistake ultimately is detected, there is a question of whether the mistake represents a method of accounting or an error. Huffman

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PODCAST

How tax reform will impact individual taxpayers

Amy Wang, a CPA who is a senior technical manager for tax advocacy at the AICPA, answers to some of the most common questions on how the new tax reform law will impact individual taxpayers.