The Supreme Court, in a 5–4 decision, held that the penalty under Section 5321 of the Bank Secrecy Act (BSA) for a nonwillful violation of the
M&A pitfalls for deferred research expenditures
Effective for amounts paid or incurred in tax years beginning after Dec. 31, 2021, the TCJA replaced the text of Sec. 174 requires taxpayers to
A primer on cancellation-of-debt income and exclusions
Unless specifically excluded under the tax law, COD income is taxable under Sec. 61. In the case of certain foreclosure transactions, the cancellation
The CHIPS Act’s semiconductor production credit
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