Ultimately, the Tax Court rejected Marvel's arguments that the plain language of Section 108 proved that Congress intended that consolidated groups use a separate-entity approach.

In a recent decision, the Tax Court held that discounts redeemable only against future purchases were deductible when redeemed rather than when earned by the taxpayer’s customers.

The Tax Court has held in favor of the taxpayer in Rent-A-Center v. Commissioner (142 TC 1), allowing Rent-A-Center to claim a Section 162 deduction for payments to a Bermuda captive insurance company.

The Tax Court has ruled in "H&M, Inc. v. Commissioner" that wages paid to an individual were not disguised purchase price payments to a corporation in connection with the sale of assets.

New final and temporary regulations under Section 385, addressing the treatment of related-party debt, significantly narrow parts of the controversial proposed regulations released in April.

Treasury and the IRS recently issued final regulations (T.D. 9737) under Section 851(c), which relates to regulated investment company (RIC) controlled group rules.

Treasury has stated that a large impetus for the proposed changes was to address base erosion and profit shifting by multinational companies.

Treasury officials said last week that the agency is still working on more guidance aimed at stemming the flow of U.S. companies reorganizing as foreign entities.

Trump has embraced the concept of a ‘border adjusted' tax, though he stopped short of specifically endorsing the border adjustability provision at the heart of the House Republican tax plan.

On the individual side, Trump proposed a full deduction of the "average cost of child care spending" and a repeal of the estate tax.

The House Ways and Means Committee approved a bill last week that would repeal the medical device excise tax. That legislation will go to the House floor the week of June 15.

Senate Finance Committee ranking minority member Ron Wyden, D-Ore., has released a discussion draft of legislation that would overhaul the tax rules on retirement accounts.

In ILM 201234026, the IRS concluded that a "go shop" provision does not alter the bright-line date for a covered transaction.

New, final regulations under Section 956 (T.D. 9792), addressing the treatment of U.S. property held by a controlled foreign corporation in connection with certain transactions involving partnerships.

On Feb. 23, 2017, the IRS released draft instructions for Form 8975, "Country-by-Country Report" and Form 8975 (Schedule A), "Tax Jurisdiction and Constituent Entity Information."

House Ways and Means Chair Dave Camp, R-Mich., continued to push tax reform last week after the president offered only tepid support for reform in his State of the Union address and top Senate taxwriter Max Baucus, D-Mont., prepared to leave Congress.

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.

For several weeks, Ryan and Hatch appeared to be abandoning efforts to pass a comprehensive tax reform bill that would lower both corporate and individual rates.

The Second Circuit Court of Appeals has affirmed the Tax Court’s decision in Union Carbide Corp. v. Commissioner (No. 11-2552), which disallowed certain supply costs used in process research activities as qualified research expenses (QREs) for purposes of the research and development (R&D) tax credit under Section 41.

Grant Thornton’s Washington National Tax Office has published a side-by-side comparison of President Barack Obama and Republication presidential candidate Mitt Romney’s positions on tax reforms.