Fixed-Asset Implications Under the American Taxpayer Relief Act of 2012
Article:
The American Taxpayer Relief Act of 2012 contains many provisions that are favorable to businesses, particularly in the fixed-asset area.
Published on April 30, 2013
Modifying or Terminating Nonqualified Deferred Compensation Plans
Article:
This article reminds readers of Sec. 409A’s general parameters and provides specific guidance on modifying or terminating existing NQDC plans.
Published on April 30, 2013
Making the Connection Between Tax and Strategic Business Decision-Making
Article:
Cross-discipline approaches can be used to expand students’ ability to apply knowledge learned in one area of accounting to other areas.
Published on April 30, 2013
Timing of Deductions for Subsidiaries Joining a New Consolidated Return
Article:
Under the consolidated return rules, special considerations apply when a subsidiary member (Sub) joins or leaves a consolidated group during the tax year.
Published on April 30, 2013
Avoiding Income Tax Credit Recapture by a Corporation
Article:
A corporation that disposes of real property may be required to increase its tax liability via a recapture of the investment tax credit or the low-income housing credit.
Published on April 30, 2013
Prop. Regs. Clarify Play or Pay Rules of the Affordable Care Act
Article:
Early this year, the IRS issued proposed regulations clarifying the “employer shared responsibility” provisions of Sec. 4980H (informally known as the “play or pay” rules).
Published on April 30, 2013
IRS Addresses Sec. 199 Requirements for Packaging Manufacturer
Article:
The exception for packaging, repackaging, labeling, or minor assembly activities does not apply to disqualify the taxpayer’s sales receipts from meeting the MPGE requirement under Sec. 199.
Published on April 30, 2013
Foreign Corporations Investing in Partnerships Common Branch Profits Tax Issues
Article:
Highlights of the tax compliance challenges that often arise as a result of U.S. branch profits tax exposure.
Published on April 30, 2013
Sec. 901(m) Potential Trap for Partnership Transactions
Article:
New Sec. 901(m) limits the creditability of foreign taxes in certain acquisition transactions where a taxpayer receives a basis step-up for U.S. tax purposes but no corresponding basis step-up for foreign tax purposes.
Published on April 30, 2013
Sec. 1202 Small Business Stock Capital Gains Exclusion
Article:
Sec. 1202 provides an opportunity for investors to make investments that could qualify for a full federal income tax exemption on a subsequent sale.
Published on April 30, 2013
Interest on Residential Property Debt Not Deductible as Investment Interest
Article:
The Tax Court held that taxpayers who purchased a residence with the intention to treat part of the tract as investment property could not deduct any of the interest on indebtedness as investment interest.
Published on April 30, 2013
New Sec. 1411 Brings Difficulty Defining Real Estate Trade or Business
Article:
The proposed regulations under Sec. 1411 do not provide a definition of “trade or business” for taxpayers engaged in rental real estate activities and thus potentially subject to the tax on net investment income on income from these activities.
Published on April 30, 2013
Time to Make a Sec. 846(e) Election to Use Company Historical Payment Patterns
Article:
Once every five years an insurer has an opportunity to elect to use its own payment pattern to discount losses (loss reserves and loss adjustment expenses) for tax purposes.
Published on April 30, 2013
Doing Business in California Substantial Economic Presence Nexus and the Throwback Rule
Article:
Technical advice raises a number of interesting issues related to California’s new definition of “doing business” and its impact on taxpayers engaging in foreign commerce.
Published on April 30, 2013
Now and Later GAAP vs. Tax Treatment of the Reinstated R&D Credit
Article:
The late reinstatement of the R&D credit has a key effect on the U.S. GAAP treatment of the credit on businesses’ 2012 financial statements.
Published on April 30, 2013