During the COVID-19 federally declared disaster, companies scrambled to come up with tax strategies that could help to curb economic losses resulting from the COVID-19 pandemic. The section 165(i) acceleration provision for...more
On June 15, 2023, the IRS released Rev. Proc. 2023-24, List of Automatic Changes, which provides an update to the list of tax accounting method changes a taxpayer may file under the IRS’s automatic procedures....more
The Tax Cuts and Jobs Act (TCJA) included a sunset provision for immediate expensing of research and experimentation (R&E) expenditures, generally providing that such expenses would be subject to five-year (domestic R&E) or...more
On June 7, 2023, the IRS released Notice 2023-42 (the Notice), providing taxpayers relief from the addition to tax under Section 6655 in connection with the application of the new corporate alternative minimum tax (CAMT). In...more
In recently issued Rev. Proc. 2023-15, the IRS provides a safe harbor method of accounting under which taxpayers may classify costs to repair, maintain, replace, or improve natural gas transmission and distribution property...more
Nearly two months ago, on August 16, 2022, President Biden signed the Inflation Reduction Act of 2022 (the IRA) into law. Among the most notable IRA provisions is a 15% corporate alternative minimum tax on corporations with...more
On August 16, 2022, President Biden signed the Inflation Reduction Act of 2022 (the IRA) into law. Among the most notable IRA provisions is a 15% corporate alternative minimum tax on corporations with book profits...more
8/18/2022
/ Alternative Minimum Tax ,
Base Erosion Tax ,
Biden Administration ,
Corporate Taxes ,
Financial Statements ,
GAAP ,
IFRS ,
Income Taxes ,
Inflation Reduction Act (IRA) ,
IRS ,
REIT ,
Tax Cuts and Jobs Act ,
Tax Rates
On July 27, 2022, the Senate announced agreement on a reconciliation package entitled the Inflation Reduction Act of 2022 (the IRA), the artist formerly known as the Build Back Better Act (the BBBA). Although months ago the...more
Section 446(e) requires a taxpayer to obtain IRS consent prior to changing its accounting method. A change in method of accounting may include either a change in an overall plan of accounting for gross income or deductions...more
On January 3, 2022, the IRS Office of Chief Counsel released an interim guidance memorandum (the Interim Guidance), along with a set of FAQs, to provide IRS Examining Agents with procedural guidance for applying Field...more
Democratic leadership announced today that an agreement has been reached to fund the pending infrastructure and budget reconciliation measures. There does not appear to be any agreement regarding which specific tax measures...more
9/24/2021
/ Biden Administration ,
Congressional Committees ,
Corporate Taxes ,
Federal Budget ,
Green Book ,
Infrastructure ,
IRS ,
Proposed Legislation ,
Reconciliation ,
Research and Development ,
Research and Experiment Tax Credit ,
Revenue Procedures ,
Tax Cuts and Jobs Act ,
Tax Deductions ,
Tax Reform
On August 12, 2021, the IRS released Rev. Proc. 2021-34, setting forth procedural guidance to implement the final Section 451 regulations (Final Regulations). The revenue procedure not only provides the terms and conditions...more
On May 24, 2021, Sen. Warren introduced Senate Bill 1788, the “Restoring the IRS Act” (the Proposed Legislation). The Proposed Legislation generally (1) imposes new information reporting obligations on financial institutions...more
6/1/2021
/ American Rescue Plan Act of 2021 ,
Biden Administration ,
Elizabeth Warren ,
Enforcement ,
False Claims Act (FCA) ,
FATCA ,
Financial Institutions ,
Internal Revenue Code (IRC) ,
IRS ,
Proposed Legislation ,
Reporting Requirements ,
Tax Avoidance ,
Tax Penalties
Recently released Revenue Procedure 2021-26 (the Revenue Procedure) provides taxpayers with guidance regarding accounting method changes made on behalf of foreign corporations. The Revenue Procedure:
..Allows controlled...more
5/27/2021
/ Accounting Methods ,
Audits ,
Controlled Foreign Corporations ,
Depreciation ,
Foreign Corporations ,
GAAP ,
GILTI tax ,
Internal Revenue Code (IRC) ,
IRS ,
Revenue Procedures ,
Tax Cuts and Jobs Act ,
Taxable Income ,
U.S. Treasury
On May 17, 2021, the Supreme Court held that the Anti-Injunction Act (AIA), section 7421(a) of the Code, does not preclude a pre-enforcement challenge to an IRS notice enforced through civil and criminal penalties. The AIA...more
5/26/2021
/ Administrative Procedure Act ,
Anti-Injunction Act ,
CIC Services LLC v IRS ,
Criminal Liability ,
Criminal Penalties ,
Federal Jurisdiction ,
Internal Revenue Code (IRC) ,
IRS ,
Notice and Comment ,
SCOTUS ,
Subject Matter Jurisdiction ,
Tax Penalties
At last week’s ABA May Tax Meeting, government attorneys from both the Internal Revenue Service National Office Income Tax & Accounting division (IT&A) and the Department of the Treasury provided updates to taxpayers and...more
5/18/2021
/ American Bar Association (ABA) ,
Biden Administration ,
Business Losses ,
Cryptocurrency ,
Financial Reporting ,
Internal Revenue Code (IRC) ,
IRS ,
Legislative Agendas ,
Priority Guidance Plan ,
Section 162(f) ,
Tax Cuts and Jobs Act ,
Tax Deductions ,
Tax Reform ,
U.S. Treasury
The Internal Revenue Service (IRS) recently issued Revenue Procedure 2021-20 (Revenue Procedure), providing guidance for taxpayers who received Paycheck Protection Program (PPP) loans in 2020 but did not deduct all of their...more
5/3/2021
/ Business Expenses ,
Business Taxes ,
CARES Act ,
Consolidated Appropriations Act (CAA) ,
Coronavirus/COVID-19 ,
IRS ,
Loan Forgiveness ,
Paycheck Protection Program (PPP) ,
Revenue Procedures ,
Revenue Rulings ,
Safe Harbors ,
Tax Deductions
On Thursday, April 8, the IRS served up Notice 2021-25 (the Notice) providing guidance for taxpayers seeking to take advantage of the temporary 100-percent deduction for the cost of business meals, which was enacted by...more
On February 25, the IRS issued a warning to taxpayers seeking to secure missed domestic production activities deductions under the now obsolete section 199. The IRS maintains that a high percentage of such claims are not...more
In light of recent Congressional action, the IRS has obsoleted its prior guidance that deductions of business expenses taken by recipients of forgiven loans under the Paycheck Protection Program (PPP) are disallowed. On...more
On Wednesday, December 23, Treasury and the IRS released final regulations under sections 263A, 448, 460, and 471 of the Internal Revenue Code (Code) to implement statutory changes made by the Tax Cuts and Jobs Act (the...more
Just in time to add to your holiday reading list, the Department of the Treasury (Treasury) and Internal Revenue Service (IRS) released final regulations under sections 451(b) and 451(c) of the Code addressing income...more
On August 14, 2020, the Internal Revenue Service (IRS) issued Rev. Proc. 2020-39 to provide guidance on the proper treatment of excess deferred taxes under the normalization provisions of section 168(i)(9) of the Internal...more
Speaking at the July 29 meeting of the ABA Section on Taxation, Practice and Procedure, Internal Revenue Service (IRS) officials and Chief Counsel shared a look behind the scenes of recent IRS implementation and enforcement...more
On July 28, 2020, the Internal Revenue Service (IRS) and Department of the Treasury (Treasury) issued final and newly-proposed regulations under section 163(j) that taxpayers and practitioners alike were eagerly awaiting....more