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National Tax Update - August 2016


CohnReznick National Tax Update Newsletter - August

 

Contact a Tax Professional
 
Corporate Tax
 
Partnership Tax
 
Accounting Periods and Methods
 
State and Local Tax
 
International Tax
 
Not-for-Profit Tax
 
Research & Development (R&D) Group
 

AUGUST 2016

A company's approach to tax planning is critical in helping it meet financial and operational objectives. CohnReznick's National Tax Update newsletter is designed to provide timely information to help you stay abreast of changing tax regulations and incentives on the local, federal, and international level.
 
We hope you find this useful in helping you adopt a comprehensive and proactive tax strategy.

 
ACCOUNTING METHODS

White House Budget Proposals for Fiscal Year 2017
 
The President’s fiscal year 2017 budget includes a number of significant tax reforms to the Internal Revenue Code. There are several business tax reform proposals designed to further the goals of efficiency, simplicity and equity within the tax code. The summary below outlines a number of key budget proposals related to tax accounting methods and small business expensing. 

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CORPORATE TAX

Taxpayer Owes Accuracy-Related Penalties for Mischaracterizing Employee Bonuses
 
The Tax Court found that a Chicago law firm owed accuracy-related penalties for deducting year-end partner bonuses that reduced its book income to zero. 

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INTERNATIONAL TAX

Proposed Section 385 Regulations Issued to Combat Corporate Inversions
 
In April 2016, the IRS issued proposed regulations pursuant to IRC section 385, as part of the effort to combat corporate inversions such as those that have occurred or been publicized over the past few years. The new regulations target post-inversion intercompany loans, which serve to “strip out” earnings from U.S. companies in the form of interest payments to a non-U.S. parent. These loans are subject to existing limitations, such as the earnings-stripping rules in section 163(j). However, perhaps due to multinationals’ successful efforts in avoiding those rules, the IRS proposed this recent batch of new rules to further limit the ability of companies to use intercompany loans to reduce U.S. tax exposure.

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