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Trends & Insights

Hong Kong Special Administrative Region “Patent Box” Overview of Tax Preferential Measures

The draft legislation on preferential tax measures for the “Patent Box” of the Hong Kong...

Reflections on the Fujian High Court on the case of Hong Kong companies transferring equity of mainland companies to enjoy agreed treatment

This case is currently one of the few public judicial judgments in China on the...

Rethinking international penalty administration

Maintaining integrity in tax administration often requires the use of penalties to encourage voluntary compliance....

Defining software development costs

The law known as the Tax Cuts and Jobs Act (TCJA), P.L. 115-97, eliminated the...

Aggregation rules affecting foreign-owned companies

Multinational businesses headquartered overseas customarily conduct operations in the United States via local subsidiaries. These...

Filing Your Startup’s Tax Return for the First Time

Filing a return for a startup for the first time can be overwhelming considering everything...

State Sales Tax Compliance for Startups

Startups face a number of challenges from hiring qualified employees, to research and development, to...

Do Startups Need Audited Financial Statements?

By law private companies are not required to undergo an annual audit of financial statements...

Redetermining foreign taxes in a post-TCJA world

The foreign tax redetermination (FTR) rules under Sec. 905(c) apply to taxpayers who accrue foreign...

Managing tax audits using sampling techniques

Sampling is a tool that is generally used whenever there is a list of records,...

Taxation of employees’ use of corporate apartments

Taxable compensation from use of an employer-provided corporate apartment Absent an applicable exclusion, the fair...

Tax fraud and bankruptcy dischargeability

The federal laws governing bankruptcy and taxation often intersect, although their makeup, effectiveness, and interpretation...

Archive

Taxation of employees’ use of corporate apartments
by Stephen Tackney, J.D., and Melissa Abel, CPA June 5, 2023
Taxable compensation from use of an employer-provided corporate apartment Absent an applicable exclusion, the fair market value (FMV) of any... Read more
Tax fraud and bankruptcy dischargeability
by Richard S. Gendler, J.D., J.S.D., LL.M.; Joel M. DiCicco, CPA/CFF, Ph.D.; George Young, CPA, Ph.D.; and Teodora Minkova, CPA June 5, 2023
The federal laws governing bankruptcy and taxation often intersect, although their makeup, effectiveness, and interpretation are significantly impacted by distinct... Read more
Nonwillful FBAR penalties apply per report, not per account
by James A. Beavers, CPA, CGMA, J.D., LL.M May 8, 2023
The Supreme Court, in a 5–4 decision, held that the penalty under Section 5321 of the Bank Secrecy Act (BSA)... Read more
M&A pitfalls for deferred research expenditures
by Seth Gee, J.D., LL.M. May 5, 2023
Effective for amounts paid or incurred in tax years beginning after Dec. 31, 2021, the TCJA replaced the text of... Read more
A primer on cancellation-of-debt income and exclusions
by Nick Gruidl, CPA, MBT; Joseph Wiener, J.D., LL.M.; and Sarah Lieberman, J.D. April 8, 2023
Unless specifically excluded under the tax law, COD income is taxable under Sec. 61. In the case of certain foreclosure... Read more
The CHIPS Act’s semiconductor production credit
by Adam Wallwork, J.D., LL.M.; Quynh Nguyen, E.A.; Gary Hecimovich, CPA; Jeremy DeMuth, J.D.; Matthew Normington, CPA; and Andrew Black, E.A. April 1, 2023
The credit, under Sec. 48D, equals 25% of qualified investment in new buildings, facilities, and other depreciable tangible property integral... Read more
Protecting contingent refund claims
by Matt Cooper, J.D.; Howard Berman, J.D.; and Teresa Abney, J.D. March 21, 2023
Taxpayers have a limited time to file refund claims with the IRS. Occasionally, this time limit may expire before the... Read more
Corporate AMT: Unanswered questions about its foreign tax credit
by Lauren Richards, CPA, MT March 7, 2023
On Dec. 27, 2022, Treasury and the IRS released Notice 2023-7, which provides taxpayers with interim guidance on the corporate... Read more
New stock repurchase excise tax
by Ethan Harris, J.D., LL.M., and Mendy Schreiber, CPA, J.D., LL.M., March 1, 2023
The Inflation Reduction Act, P.L. 117-169, was signed into law on Aug. 16, 2022. The act included a new Sec.... Read more
Current developments in partners and partnerships
by Hughlene A. Burton, CPA, Ph.D. February 28, 2023
Court cases decided during the reviewed period dealt with issues under the former unified audit rules of the Tax Equity... Read more
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