Protecting contingent refund claims
Taxpayers have a limited time to file refund claims with the IRS. Occasionally, this time limit may expire before the taxpayer’s right to the refund
Corporate AMT: Unanswered questions about its foreign tax credit
On Dec. 27, 2022, Treasury and the IRS released Notice 2023-7, which provides taxpayers with interim guidance on the corporate AMT. Taxpayers may rely
New stock repurchase excise tax
The Inflation Reduction Act, P.L. 117-169, was signed into law on Aug. 16, 2022. The act included a new Sec. 4501 that imposes an excise tax on
Current developments in partners and partnerships
Determining gross receipts under Sec. 165(g)(3)
The IRS ruled in Letter Ruling 202140002 (released Oct. 8, 2021) that a corporation included the historic gross receipts of its liquidated subsidiary
Proposed regs. address IRS Appeals’ review of tax controversies
Treasury and the IRS have proposed regulations (REG-125693-19) to clarify the types of federal tax controversies that may be appealed to the IRS
Sec. 987 foreign currency regulations applicability date extended again
On Aug. 15, 2022, the IRS announced (Notice 2022-34) that it intends to defer by one more year the applicability date of certain foreign currency
Inflation Reduction Act includes 15% corporate minimum tax on book income
On Aug. 16, 2022, President Biden signed into law the Inflation Reduction Act, P.L. 117-169. For applicable corporations that report over $1 billion