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The IRS has released an internal legal memorandum (ILM 2012-26-015) outlining how it approaches questions regarding whether receipts for licensing or selling "cloud"-based software qualify as domestic production gross receipts (DPGRs) for purposes of the Section 199 domestic production activities deduction (DPAD).

The House and Senate Budget Committees both approved budget resolutions last week that would allow the tax-writing committees to use reconciliation procedures to expedite tax legislation.

In the first of what is nearly certain to be a long line of cases, the U.S. Tax Court ruled in Walker v. Commissioner, T.C. Summ. Op. 2017-50, that a couple who received an advanced premium tax...

The Tax Court held that WRIC's election to treat AIS as a QSUB did not result in an item of income.

2013 brought the biggest tax changes in more than a decade.

The Fifth Circuit Court of Appeals affirmed that the portion of a note attributable to unrealized receivables was not eligible for the installment method.

The FASB Board discussed the following topics related to proposed changes to the guidance for accounting by investment companies.

In "VECO Corp. et al. v. Commissioner", the Tax Court rejected a taxpayer’s proposed change in accounting method because the court determined that the all-events tests had not been met for some deductions.

Between 1999 and 2000, AmerGen purchased three nuclear plants: Three Mile Island, Clinton Power Station and Oyster Creek Nuclear Generating System.

A U.S. district court has denied the IRS’s motion for partial summary judgment in the ongoing research and development (R&D) tax credit litigation in Bayer Corp. v. United States (No. 2:09-cv-00351). In the ruling, the U.S. Western District Court of Pennsylvania disagreed with the IRS’s arguments that Bayer substantially varied the factual basis for the R&D credits at issue.

Republicans are considering new ways to enact a series of trade initiatives with tax revenue raisers after congressional Democrats blocked the bills in a series of votes.

The Court of Appeals for the Eighth Circuit affirmed a district court’s decision denying the taxpayer a bank a capital loss and corresponding tax refund from the carryback of the capital loss because the underlying transaction was a sham that lacked both economic substance and a business purpose.

The IRS Office of Chief Counsel addressed whether an S corporation and its wholly owned qualified subchapter S subsidiary must prorate annual income.

The IRS has released field attorney advice that authorizes a negligence penalty on a taxpayer for taking the position that an open-air garage is a land improvement and therefore has a 15-year recovery period.

The IRS has concluded in a legal memorandum that the installation of exterior heating, ventilation and air conditioning units on roofs and concrete pads next to buildings does not meet the definition of a qualified leasehold improvement property under Section 168(e)(6).

The IRS has concluded in a legal memorandum that an individual's guarantee was an amount at-risk for purposes of Section 465.

The IRS has concluded in a legal memorandum (ILM 2012-38-025) that a taxpayer was considered a dealer in securities under Section 475(c) because it purchased debt and subsequently sold such debt as part of its securitization activity.