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...Nonwillful FBAR penalties apply per report, not per account
The Supreme Court, in a 5–4 decision, held that the penalty under Section 5321 of...M&A pitfalls for deferred research expenditures
Effective for amounts paid or incurred in tax years beginning after Dec. 31, 2021, the...Archive
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
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
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
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
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
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
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
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
February 1, 2023
The IRS ruled in Letter Ruling 202140002 (released Oct. 8, 2021) that a corporation included the historic gross receipts of... Read more
January 11, 2023
Treasury and the IRS have proposed regulations (REG-125693-19) to clarify the types of federal tax controversies that may be appealed... Read more