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Generally Accepted Accounting Procedures › Internal Revenue Service

Generally Accepted Accounting Principles (GAAP) are accounting standards and procedures that are used by companies within a particular jurisdiction to prepare financial records and statements. These principles... more +
Generally Accepted Accounting Principles (GAAP) are accounting standards and procedures that are used by companies within a particular jurisdiction to prepare financial records and statements. These principles are intended to create consistency in documentation across companies and industries. Consistent documentation assists investors to better analyze potential investments and assists regulators to detect potential fraud and/or wrongdoing. less -
Eversheds Sutherland (US) LLP

Be careful what you wish for: IRS and Treasury release goliath CAMT NPRM full of nuance and complexity

Eversheds Sutherland (US) LLP on

On September 12, 2024, the Internal Revenue Service and Department of the Treasury (collectively, the Government) issued long-awaited proposed regulations (the NPRM), providing guidance regarding application of the corporate...more

Allen Barron, Inc.

The Tax Consequences of Offshore Mutual Funds for US Expats and Taxpayers

Allen Barron, Inc. on

What are the tax consequences of offshore mutual funds for US expats and taxpayers? US expatriates have faced a substantial number of challenges over the past several years as a result of FATCA. It can be hard to simply open...more

Holland & Knight LLP

IRS Rules Utility's NOL Carryforward Cannot Be Reduced by Tax Allocation Payments

Holland & Knight LLP on

The IRS recently issued private letter ruling (PLR) 107770-22 that involved a normalization issue of first impression, namely, whether payments received by a utility pursuant to an intercompany tax allocation agreement (TAA)...more

Allen Barron, Inc.

IRS Audit Doesnt Have to Be a Nightmare

Allen Barron, Inc. on

An IRS audit doesn’t have to be a nightmare of financial and emotional fear. How do most US taxpayers react when they receive an audit letter from the IRS? What are the actions you can take to not only improve the likelihood...more

Allen Barron, Inc.

What Happens If You Don't File an FBAR

Allen Barron, Inc. on

It is common for a US taxpayer to ask “what happens if you don’t file an FBAR or a Form 8938, Statement of Specified Foreign Assets with the IRS? Why do I have to worry about filing an FBAR in San Diego or anywhere in the US,...more

Cadwalader, Wickersham & Taft LLP

A Worthwhile Proposal for Worthless Debt

Cadwalader, Wickersham & Taft LLP on

In December, Treasury and the IRS issued proposed regulations updating the standard for determining when a debt instrument held by certain banks and insurance regulated entities will be conclusively presumed to be worthless...more

Allen Barron, Inc.

Is it Time to Rethink Your Offshore PFIC Investment(s)?

Allen Barron, Inc. on

Is it time to rethink your offshore PFIC investment(s)? What is a PFIC and why should you be concerned about the impact it will have upon taxation? Why should investment in a PFIC concern you as a US taxpayer?...more

Vinson & Elkins LLP

[Hybrid Event] The New Corporate AMT and Attorney/Client Privilege: Why Your Attorney Should Hire Your Accountant - January 12th,...

Vinson & Elkins LLP on

The new corporate alternative minimum tax (“CAMT”) generally applies to corporations with 3-year average “book” income in excess of $1 billion. Thus whether a corporation owes CAMT may depend on positions taken under GAAP....more

Tucker Arensberg, P.C.

Pennsylvania Personal Income Tax Will Follow Federal Rules for Like Kind Exchanges under Internal Revenue Code Section 1031 for...

Tucker Arensberg, P.C. on

The accounting rules for the Pennsylvania Personal Income Tax do not follow the Federal Tax Code. Instead, they follow generally accepted accounting principles....more

Eversheds Sutherland (US) LLP

Signed, sealed, delivered: Biden signs Inflation Reduction Act enacting “new” corporate minimum tax

Eversheds Sutherland (US) LLP on

​​​​​​​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

ArentFox Schiff

Key Tax Changes Impacting Businesses in the New Inflation Reduction Act

ArentFox Schiff on

Today, President Joe Biden signed into law the Inflation Reduction Act of 2022 (the “Act”). Although the proposal further restricting the availability of long-term capital gain treatment with respect to carried interests...more

Lowenstein Sandler LLP

Inflation Reduction Act Tax Implications

Lowenstein Sandler LLP on

The President is expected to imminently sign the Inflation Reduction Act of 2022 (the “Act”), which was passed by both the Senate and House of Representatives. This Client Alert addresses two main tax provisions in the...more

Lowenstein Sandler LLP

Plan Fiduciaries, Including Investment Advisers and Fund Managers, Take Note – U.S. Department of Labor Proposes Enhanced QPAM...

Lowenstein Sandler LLP on

On July 26, 2022, the U.S. Department of Labor (DOL) released a proposed amendment to Prohibited Transaction Class Exemption 84-14, known as the Qualified Professional Asset “Manager” (QPAM) exemption. ...more

Freeman Law

Tax Court in Brief: Lord v. Comm’r—Marijuana and COGS

Freeman Law on

The Tax Court in Brief – February 28th-March 4th, 2022 Freeman Law’s “The Tax Court in Brief” covers every substantive Tax Court opinion, providing a weekly brief of its decisions in clear, concise prose. ...more

ArentFox Schiff

Investigations Newsletter: DOJ Attorneys Comment on the Rise of Telehealth Fraud During the COVID-19 Pandemic

ArentFox Schiff on

DOJ Attorneys Comment on the Rise of Telehealth Fraud During the COVID-19 Pandemic - During the 2022 Qui Tam Conference of the Federal Bar Association, DOJ attorneys commented on the dramatic rise in the use of remote...more

McDermott Will & Emery

The 90 Percent Test

McDermott Will & Emery on

Since coming into effect in January 2018, Subchapter Z of the US Tax Code—also known as the opportunity zone provisions—has enabled investors to pour billions of dollars into a broad array of businesses, from real estate...more

Eversheds Sutherland (US) LLP

Rev. Proc. 2021-26 provides accounting method change procedures for CFCs seeking to use the alternative depreciation system

Eversheds Sutherland (US) LLP on

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

Foley & Lardner LLP

ARPA Funding Relief for Single Employer Defined Benefit Pension Plans

Foley & Lardner LLP on

On March 11, 2021 President Biden signed the American Rescue Plan Act (Public Law 117-2) ("ARPA"). Among its many provisions, the statute contains "funding relief" for single employer defined benefit pension plans. This...more

McDermott Will & Emery

Proposed Regulations Would Conform Subpart F High-Tax Exception to GILTI High-Tax Exception

McDermott Will & Emery on

On July 20, 2020, the US Department of the Treasury (Treasury) and the Internal Revenue Service (IRS) issued proposed regulations (REG-127732-19) (the 2020 Proposed Regulations) that would conform the historic Subpart F...more

Eversheds Sutherland (US) LLP

IRS offers a 162(m) - brace for the holidays

Eversheds Sutherland (US) LLP on

On December 16, 2019, the Department of the Treasury (Treasury Department) and Internal Revenue Service (IRS) released long-awaited proposed regulations under Section 162(m) of the Internal Revenue Code implementing changes...more

Smith Anderson

Draft North Carolina Tax Legislation Released

Smith Anderson on

On April 11, 2018, the General Assembly’s Revenue Laws Study Committee released a draft tax bill for possible introduction in the legislative session that convenes May 16. This Alert provides a summary of the more important...more

Sheppard Mullin Richter & Hampton LLP

Congress Passes Final Tax Reform Bill: U.S. Tax Reform: The Current State of Play

Sheppard Mullin Richter & Hampton LLP on

With the affirmative vote in the House today, both Houses of Congress have now passed a final version of the Tax Cuts and Jobs Act, clearing the legislation for President Trump’s signature. President Trump is widely expected...more

Akin Gump Strauss Hauer & Feld LLP

Investment Management Special Report - 2017-18 Compliance Developments & Calendar for Private Fund Advisers

Akin Gump Strauss Hauer & Feld LLP on

Introduction - Despite an anticipated de-regulatory push, there are significant new regulatory concerns for investment advisers to address in connection with their annual review of their compliance manuals. ...more

Farrell Fritz, P.C.

Deducting Payments Between Related Parties

Farrell Fritz, P.C. on

Potential for Abuse- Many years ago, Congress decided that taxpayers who were “related” to one another should be required to use the same accounting method with respect to transactions between them in order to prevent the...more

Latham & Watkins LLP

New Final Inversion Rules Maintain Tight Standard for Corporate Expatriations

Latham & Watkins LLP on

For expatriating US companies to avoid anti-inversion rules, their foreign business activities must satisfy a tough bright-line test, consistent with controversial 2012 rules. On June 3, 2015, the US Department of the...more

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