News
February 2026
17+ hour, 14+ min ago (121+ words) Just as for other businesses, tax considerations come to the fore when CPA practices combine. This article delves into some of the possible entity deal structures for CPA firm mergers and acquisitions and the potential tax issues they present. Deductibility…...
Partner redemptions from ‘dry’ partnerships
17+ hour, 14+ min ago (141+ words) Editor: Greg A. Fairbanks, J.D., LL.M. The first and perhaps simplest method of funding the redemption of a partner from a dry partnership is for the corporation to distribute funds to the partnership, which in turn uses the cash to redeem its partner....
IRS removes associated-property rule from interest capitalization regulations
17+ hour, 14+ min ago (154+ words) Editor: Greg A. Fairbanks, J.D., LL.M. Including the basis of associated property in production expenditures results in the capitalization of more interest to improvements to designated property under Sec. 263A(f), as the adjusted basis increases the base of production expenditures for calculating the amount…...
Practical tax issues related to qualified reopenings
17+ hour, 14+ min ago (448+ words) Editor: Greg A. Fairbanks, J.D., LL.M. If the additional debt is a qualified reopening of the original debt, the original debt and the additional debt are regarded as fungible and treated as a single debt for tax purposes. If the additional debt is…...
Deductibility of transaction costs incurred by an indirectly acquired entity
17+ hour, 14+ min ago (165+ words) Editor: Greg A. Fairbanks, J.D., LL.M. In connection with the transaction, the taxpayer engaged a financial adviser to assist in investigating and pursuing the transaction. The financial adviser's fees were contingent upon the successful closing of the transaction, and the financial adviser was…...
IRS issues guidance on treaty application to reverse foreign hybrids
17+ hour, 14+ min ago (372+ words) Editor: Greg A. Fairbanks, J.D., LL.M. The IRS concluded that such a reverse hybrid entity may qualify for a reduced rate of BPT under the applicable U.S. federal income tax treaty on the portion of the entity's dividend equivalent amount (DEA) corresponding to interests…...
Prop. regs. issued on new qualified tips deduction
1+ mon, 17+ hour ago (332+ words) Editor: Susan M. Grais, CPA, J.D., LL.M. Treasury and the IRS in September released proposed regulations (REG11003225) with guidance on the new federal income tax deduction for tips, which was enacted in H.R. 1, P.L. 11921, known as the One Big Beautiful Bill Act (OBBBA), for tax years…...
IRS rules for first time that REIT’s income from markup on electricity from EV charging stations is rents from real property
1+ mon, 17+ hour ago (436+ words) Editor: Susan M. Grais, CPA, J.D., LL.M. The ruling marks the first time the IRS addressed whether a REIT's markup on electricity drawn from electric vehicle charging stations (EV stations) constitutes rents from real property. The taxpayer, a limited liability company that intends…...
IRS rules that community trust and affiliated nonprofit corporation can file a single Form 990
1+ mon, 17+ hour ago (343+ words) Editor: Susan M. Grais, CPA, J.D., LL.M. Regs. Sec. 1.170A9(f)(11)(iii) requires an organization to be commonly known as a community trust, fund, foundation, or other similar name showing the fund supports charitable activities in the community or area it serves. Regs. Sec. 1.170A9(f)(11)(iv) requires all…...
January 2026
1+ mon, 17+ hour ago (136+ words) This article explores the strategic use of this election, highlighting its potential to optimize tax outcomes for both trusts and beneficiaries while cautioning against its pitfalls. IRS generally eliminates 5% safe harbor for determining beginning of construction for wind and solar…...