On November 29, 2018, the Internal Revenue Service (IRS) issued Rev. Proc. 2018-60, which provides automatic accounting method change procedures for taxpayers seeking to comply with section 451(b), relating to the timing of...more
12/11/2018
/ Accrual Method ,
Audited Financial Statements ,
Corporate Taxes ,
Financial Accounting ,
Financial Statements ,
Income Taxes ,
Internal Revenue Code (IRC) ,
IRS ,
Revenue Procedures ,
Tax Cuts and Jobs Act ,
Tax Reform
On November 26, 2018, the Department of the Treasury (Treasury) and the Internal Revenue Service (IRS) issued much-anticipated proposed regulations (Proposed Regulations) under section 163(j) of the Internal Revenue Code of...more
On November 19, 2018, the Internal Revenue Service (IRS) and the Treasury Department (Treasury) issued final regulations (T.D. 9843) that address taxpayers’ use of negative amounts in calculating additional costs for purposes...more
As part of the Tax Cuts and Jobs Act of 2017, Congress enacted sections 1400Z-1 and 1400Z-2 of the Internal Revenue Code, which were intended to promote investments in low-income communities designated as “Opportunity Zones.”...more
On October 3, the Internal Revenue Service (IRS) issued Notice 2018-76 (the Notice) to address the deductibility of business meals under section 274(a) of the Internal Revenue Code. The Tax Cuts and Jobs Act (the TCJA) made...more
Last year, the federal government enacted the most substantial tax reform legislation since 1986 in Public Law 115-97, commonly referred to as the Tax Cuts and Jobs Act of 2017 (TCJA). Of the many business-friendly changes,...more
On August 1, 2018, the Department of Treasury and the Internal Revenue Service (IRS) issued proposed regulations implementing section 965 of the Internal Revenue Code (Code) (referred to as the “transition tax”). Section 965...more
On June 21, 2018, the Internal Revenue Service (IRS) issued Chief Counsel Advice (CCA) 2018-30-011, which disallowed a taxpayer’s deduction of a portion of a success-based fee incurred in a corporate transaction because the...more
On May 10, 2018, the Internal Revenue Service (IRS) issued Rev. Proc. 2018-29, 2018-21 I.R.B. 1, which provides automatic accounting method change procedures for taxpayers seeking to align methods of income recognition for...more
On May 10, 2018, the Internal Revenue Service (IRS) released Rev. Proc. 2018-31, which provides an updated list of automatic changes in methods of accounting. As was the case with its predecessor, Rev. Proc. 2017-30, the list...more
On April 12, 2018, the Treasury Department and the Internal Revenue Service (IRS) issued Notice 2018-35 (Notice) that provides transitional guidance relating to advance payments under Rev. Proc. 2004-34. Despite the...more
The Treasury Department and the Internal Revenue Service (IRS) issued Notice 2018-26, which provides guidance under section 965 of the Internal Revenue Code regarding the “transition tax.” Section 965 imposes a transition tax...more
4/10/2018
/ Accounting Methods ,
Controlled Foreign Corporations ,
Corporate Taxes ,
Foreign Earned Income ,
Foreign Subsidiaries ,
Income Taxes ,
International Tax Issues ,
IRS ,
Shareholders ,
Subpart F ,
Tax Rates
On March 27, 2018, the Internal Revenue Service (IRS) issued Notice 2018-23 (the Notice), providing transitional guidance for parties to suits and agreements covered by sections 162(f) and 6050X of the Internal Revenue Code...more
New Campaigns Announced -
On March 13, 2018, the Large Business and International (LB&I) Division of the Internal Revenue Service (IRS) announced five new compliance campaigns. The new campaigns continue the IRS’s move to...more
On March 13, 2018, the Large Business and International (LB&I) Division of the Internal Revenue Service (IRS) announced five new compliance campaigns. The announcement of these new campaigns reiterates LB&I’s efforts to focus...more
New Campaigns Announced -
On March 13, 2018, the Large Business and International (LB&I) Division of the Internal Revenue Service (IRS) announced five new compliance campaigns. The five campaigns supplement the 13 initial...more
On October 23, 2017, the Internal Revenue Service Office of Chief Counsel (Chief Counsel) concluded that certain merchant discount fees earned by a parent company in a consolidated group did not constitute domestic production...more
The Internal Revenue Service (Service) issued PLR 201739003 on September 29, 2017, in which it granted an extension to a taxpayer that failed to timely file for the safe-harbor election provided in Rev. Proc. 2011-29, 2011-1...more
On September 7, 2017, the IRS issued Revenue Procedure 2017-47, which provides a safe harbor for regulated public utilities for inadvertent or unintentional uses of a practice or procedure that is inconsistent with the...more
On April 19, 2017, the Internal Revenue Service (IRS) released Rev. Proc. 2017-30, 2017-17 I.R.B. 1, which provides an updated list of automatic changes in methods of accounting. As was the case with its predecessor, Rev....more
Although the cost of obtaining regulatory approval for a corporate transaction is identified as facilitative, a recent Chief Counsel Advice (CCA 2017-13-010, March 31, 2017) (the CCA) issued by the Internal Revenue Service...more
In the last few weeks, the Internal Revenue Service (the Service) issued several private letter rulings addressing a variety of tax accounting issues. From bonus depreciation elections to the correct unit of property for...more
On December 20, 2016, the Internal Revenue Service (the Service) issued Notice 2017-6, which provides relief for a taxpayer seeking to change accounting methods in connection with the final tangible property regulations...more
On July 6, the Internal Revenue Service (IRS) Large Business and International Division issued a Directive1 to IRS agents regarding how to determine when a major component pertaining to steam or electric generation property...more