One of the more significant issues that taxpayers and tax practitioners have faced in recent months is the Tax Cuts and Jobs Act’s (TCJA) amendment to Section 174, requiring capitalization of previously deductible R&D and...more
Taxpayers typically incur significant transaction costs when undergoing a transaction involving a restructuring, acquisition, disposition, sale of assets, or sale of stock. The default rule under section 263 is that all...more
Come tax time, taxpayers in the marijuana industry in Oregon may want to proceed with caution. Since Oregon is tied to the Internal Revenue Code—specifically IRC § 280E—for purposes of income taxation, deductions relating to...more
Progress always requires change, and progress in the way we tax tangible property is no exception. The tangible property rules have long been one of the murkier areas of the federal tax code. But new regulations — the last...more
The Office of the Chief Counsel of the Internal Revenue Service has issued a Legal Memorandum (Number AM2013-001, dated March 1, 2013) (the “Memorandum”), which has important implications and represents a victory for lenders...more
The Assessment Appeals Commission (“AAC”) of the Tennessee State Board of Equalization has reversed a 2011 administrative law judge decision, holding that intangible costs (such as freight, installation, engineering costs and...more