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
Welcome relief to taxpayers with short tax years seeking to file Section 174 accounting method changes -
On August 29, 2024, the Internal Revenue Service (IRS) and Department of the Treasury (Treasury) released Rev. Proc....more
On June 21, 2024, the Internal Revenue Service (IRS) released an early draft of revised Form 6765, Credit for Increasing Research Activities. Following the release of the September 2023 draft Form 6765 which dramatically...more
On April 30, 2024, the Internal Revenue Service (IRS) released Rev. Proc. 2024-23, List of Automatic Changes, which provides the list of tax accounting method changes a taxpayer may file under the IRS’s automatic procedures,...more
On April 26, 2024, IRS Chief Counsel, Income Tax & Accounting (IT&A), released a legal memorandum (ILM) addressing the treatment of credit card reward liabilities for which a customer earns rewards that can be redeemed for...more
In mid-January, the House introduced the Tax Relief for American Families and Workers Act (Act). The Joint Committee of Taxation has released its explanation of the Act, and the House Ways and means Committee has released a...more
1/31/2024
/ Affordable Housing ,
Congressional Committees ,
Filing Requirements ,
FIRPTA ,
Foreign Corporations ,
Low Income Housing ,
Mortgage REITS ,
Proposed Legislation ,
Relief Measures ,
Taiwan ,
Tax Credits ,
Tax Cuts and Jobs Act ,
Tax Extenders ,
Tax Treaty
Businesses have entered 2024 facing the challenge of forecasting future tax obligations and preparing tax filings in a time of uncertainty, not the least of which is created by Congressional indecision on the future of a...more
Not unlike the last minute procedural guidance released at the end of last year addressing Section 174, on December 22, 2023, the Department of the Treasury (Treasury) and the Internal Revenue Service (IRS) released Notice...more
On December 1, 2023, the Internal Revenue Service (IRS) released two private letter rulings (PLRs) that considered taxpayer requests to file an extension of time to make a regulatory election within the meaning of Treas. Reg....more
In FAA 20234801F (FAA), the IRS determined that construction service costs relating to a third party turn-key contract were considered to be incurred upon transfer of the tangible property to the taxpayer, without taking into...more
At this morning’s Federal Bar Association breakfast briefing hosted by Eversheds Sutherland, officials from the Internal Revenue Service (IRS) and Department of the Treasury (Treasury) discussed the recent substantive...more
On September 12, 2023, the Internal Revenue Service (IRS) and Department of the Treasury (Treasury) released a third substantive piece of guidance, Notice 2023-64 (Notice) clarifying the application of the new corporate...more
The long wait for substantive guidance under Section 174 ended late last week with the release by the Department of the Treasury (Treasury) and the Internal Revenue Service (IRS) of Notice 2023-63 (Notice). Taxpayers may rely...more
9/12/2023
/ Capital Expenditures ,
Interim Guidance ,
IRS ,
Proposed Regulation ,
Research and Development ,
Revenue Procedures ,
Software ,
Software Developers ,
Tax Cuts and Jobs Act ,
Technology Sector ,
U.S. Treasury
In an opinion released July 27, 2023, the Third Circuit affirmed a 2021 Tax Court decision upholding a pharmaceutical company’s immediate deduction of patent defense litigation costs in suits brought under the Hatch-Waxman...more
8/1/2023
/ Abbreviated New Drug Application (ANDA) ,
Food and Drug Administration (FDA) ,
Hatch-Waxman ,
IRS ,
Mylan Pharmaceuticals ,
Patent Infringement ,
Patent Litigation ,
Patents ,
Pharmaceutical Industry ,
Pharmaceutical Patents ,
Tax Court ,
Tax Deductions
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