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In Notice 2015-59, the IRS announced there are several areas that are currently under study based upon characteristics of certain Section 355 spin-offs that concern the IRS due to possible abuse.

This past summer under the Inflation Reduction Act, Congress enacted new Internal Revenue Code ("Code") Section 4501, which imposes an excise tax on certain corporate redemptions...

The IRS reported in November of 2009 that over 14,000 taxpayers entered the special voluntary disclosure program for offshore accounts. That program deadline expired on October 15, 2009.

The Tax Cuts and Jobs Act, which was enacted on December 22, 2017, had a significant one-time impact on the net income of many U.S. companies that was reported after that date.

The IRS has issued the 2016 optional standard mileage rates for calculating the deductible costs of operating an automobile for business, charitable, medical, and moving purposes (Notice 2016-1; IR-2015-137).

While taxes are one of the two certainties in life, right alongside death, the issues that organizations face can vary drastically.

The IRS has issued proposed regulations to modify existing rules on gain recognition agreement reporting.

The research and development (R&D) tax credit has been extended through 2013 as part of the American Taxpayer Relief Act of 2012, and the legislation makes several modifications in how the credit is computed for controlled groups and how acquisitions are treated.

Mark Twain is often quoted as saying that "everybody talks about the weather, but nobody does anything about it."

One often overlooked debt-equity issue is presented by continuing transfers to a subsidiary that is reasonably creditworthy at the inception but subsequently encounters difficulties, in spite of which (or maybe because of which) and continues to receive advances from the common parent or one of its finance subsidiaries.

The Senate Finance Committee released five reports from its tax reform working groups this week that offer recommendations for international and business tax reform.

Taxpayers wishing to claim cash grants in lieu of a Section 48 energy investment credit for alternative energy property must file applications with the IRS no later than Sept. 30, 2012, whether or not the property has been placed in service.

On August 26, the US Court of Appeals for the Seventh Circuit joined a majority of circuits in holding that a taxpayer who overstates basis and participates in a sham transaction can be held liable for the forty-percent valuation misstatement penalty under section 6662(h).

The Multistate Tax Commission has undertaken an ambitious project on the state taxation of partnerships.

On October 17, 2013, Swiss Bank Frey & Co. AG announced that it had decided to cease business activities as a bank stemming from "increasingly difficult market conditions, ever-growing regulations and the unsustainable requirements that smaller private banks are required to comply with" related to the tax dispute with the United States. Dr. Markus Frey, Chairman of the Board, stated that "[a]s a result of developments in recent years, circumstances and challenges have presented themselves, espec

The Tax Court in Stough v. Commissioner (144 T.C. No. 16) sustained an accuracy-related penalty for a taxpayer's treatment of a lump sum payment received under the terms of a lease agreement.

As 2014 came to an end, restaurant businesses everywhere waited on several tax breaks that can be beneficial on their 2014 tax returns.