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Four Tax Considerations Before Selling a Business
Feb 1, 2020
The current tax regime may have owners of middle-market companies thinking of selling their business. 2020 promises a testy election season; a change in the political balance could mean significant tax changes. This article features a review of the main tax impacts based on entity and transaction type.
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More Audit Campaigns Announced by the IRS Large Business and International Division
Oct 13, 2020
A brief synopsis of recent audit campaigns initiated by the IRS Large Business and International Division.
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Tax Considerations of IRS Proposed Rules on Digital and Cloud Transactions
Nov 26, 2019
A discussion of the Internal Revenue Service’s proposed regulations on federal income tax treatment for cloud-based transactions.
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Final Interest Limitation Regulations
Aug 26, 2020
This article discusses key aspects of the final regulations, including the clarification of the definition of interest for purposes of the limitation; the impact on the calculation of adjusted taxable income from sales of depreciable assets; and the impact on the calculation of ATI from depreciation and amortization expense that was capitalized to inventory.
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Oct 17, 2019
A discussion of the IRS’s move that should calm concerns over the potential tax consequences of the impending transition to the use of reference interest rates other than interbank rates (“IBORs”) in debt instruments and non-debt contracts.
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Post-Election Business Tax – What’s on the Horizon?
Dec 11, 2020
This articles features discussion of the likely tax landscape, post-election and over the next few years.
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Partnerships Remain High on the IRS Radar (Part 1)
Jul 22, 2020
The IRS’ Bipartisan Budget Act Audit Roadmap is the latest in a series of actions signaling its intention to audit more partnerships. It generally applies to all partnerships required to file a Form 1065, U.S. Return of Partnership Income.
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4 Questions to Assess ‘Personal Goodwill’ in a C Corporation Asset Sale
Mar 21, 2019
With M&A activity on the rise, corporations may be looking for the most tax-advantageous exit strategy. The right professional team will provide insights for structuring a corporate sale in the most tax-efficient way.
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Two Big Missteps of Previous Cryptocurrency Winners
Jul 2, 2019
Cryptocurrency is moving into the mainstream and should compel individuals to familiarize themselves with cryptocurrency’s tax treatment in order to avoid mistakes.
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Three Biggest Surprises of the R&D Tax Credit
Jul 3, 2019
There are 3 surprises of the R&D Tax Credit. Technology companies as well aas emerging and established businesses across diverse industries may also take advantage of this benefit.
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Pass-Through Business Alternative Income Tax Act
Jan 15, 2020
A discussion of NJ SB3246, the “Pass-Through Business Alternative Income Tax Act, enacting some type of entity-level tax on pass-through entities (“PTEs”) in an effort to work around the $10,000 federal cap on individuals’ itemized deductions for state income taxes.
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Tax Considerations of New Lease Accounting Rule ASC 842
Nov 26, 2019
A discussion of the tax impact of lease accounting rule ASC 842, including Finance vs. Operating Leases, accounting and tracking impacts, and state-level impacts
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Further Audit Campaigns Announced by the IRS Large Business and International Division
Jul 26, 2019
The IRS Large Business and International Division identified six additional audit compliance campaigns on July 19, 2019. These audit compliance campaigns focus on international issues, S corporations and deferred compensation.
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Three Additional Large Business and International Compliance Campaigns Announced by IRS
Apr 17, 2019
Three compliance campaigns were announced by the IRS Large Business and International Division to improve return selection, identify issues representing a risk of non-compliance, and make the greatest use of limited resources.
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Business Tax Quarterly Executive Summary Fall 2019
Nov 25, 2019
Business Tax Quarterly discusses two business matters including the IRS-proposed guidance on digital content and cloud transactions, and recent updates to ASC 842 lease accounting standards.
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Final Regulations Issued on Charitable Contributions in Exchange for State and Local Tax Credits
Jun 18, 2019
The IRS issued final regulations under IRC Sec. 170 on state and local charitable contribution tax credit programs. Regulations assist with charitable contributions.
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IRS Issues New Final and Temporary Regulations on “Dividend Equivalent” Payment Withholding
Oct 22, 2020
IRS regulations regarding withholding on US-source 'dividend equivalents' and the formalization of a 'delta' based approach for certain dividend equivalent payments made on or after 1/1/17. Info on the background and final regulations on dividend equivalent payment withholding.
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Jan 2, 2017
Closely held businesses need to be aware of the valuation requirements related to stock and appreciation right grants under section 409A to avoid the extremely harsh tax consequences imposed on the employee for failure to comply with these rules.
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IRS Extends Implementation Deadline for Certain Limited Aspects of FATCA
Sep 25, 2015
The IRS extended the implementation deadline for certain limited aspects of FATCA. In order to comply with FATCA’s information reporting objectives and avoid 30% withholding, investment funds and other foreign financial institutions must do the following.
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Apr 3, 2014
Internal Revenue Code Section 831(b) and Small Captive Insurance Companies a must do or an IRS target? Establishing a small captive insurance company may be appropriate but it requires careful analysis before implementation. What is captive insurance and what are the potential benefits and risks?