No. 56-9, September 2025
Index
- Company's $1.6 billion 'break fee' payment treated as ordinary deduction.
- Current developments in taxation of individuals: This update surveys recent federal tax developments involving individuals, including court cases, rulings, and guidance issued during the six months ending April 2025. (part 1)
- IRS ruling clarifies treatment of R&D when computing the FDII deduction. (research and development services in foreign-derived intangible income computation)
- Leadership in tax practice: Inspiring teams and driving growth amid industry change - Amid turbulence in the tax profession, firm leaders can impart clarity, empathy, and inspiration to inculcate lasting loyalty and success.
- Like-kind exchanges of real estate: Building on the basics.
- New legislation seeks to address disaster relief refund claim discrepancies.
- Outlier or beginning of a trend? Illinois redefines investment partnerships.
- P.L. 86-272 and the evolution of nexus in the digital age. (Interstate Income Tax Act of 1959)
- Partnership recapitalization: Lender admittance without liability reduction.
- Planning with charitable remainder trusts.
- Supreme Court: Tax Court lacks jurisdiction when levy is satisfied.
- Technology and tax standards: Understanding new SSTS Section 1.4 - Reliance on Tols. (Statements on Standards for Tax Services)
- The R&D tax credit for architects and engineers: Architecture and engineering firms often face challenges when seeking to claim the Sec. 41 research-and-development tax credit for their work on building and construction projects, as two recent court cases illustrate. However, by understanding the requirements to claim the credit and carefully planning, executing, and substantiating a project, they may be able to qualify for it.
- Transactions between related parties.