To protect against certain risks, businesses can create βcaptiveβ insurance companies. The final regulations designate certain microcaptive arrangements as reportable listed transactions or transactions of interest.
Deductions
Taxpayer denied theft loss deduction for investment loss
The Tax Court focused on the taxpayerβs role as president and managing director of the company in which he invested, along with his failure to prove a theft occurred.
Burden of proof: The shoebox method and 9-martini lunch
When taxpayers claim deductions for business expenses, they must meet their burden of proof with proper recordkeeping.
Dealing with sales between related persons
Losses may be disallowed for sales or exchanges between related parties.
Planning opportunities: Sec. 179 expensing vs. bonus depreciation
As bonus depreciation phases out, practitioners need to consider Sec. 179 expensing to maximize deductions on fixed-asset purchases.
Annual inflation adjustments announced for tax year 2025
The IRS on Tuesday provided its annual inflation adjustments for over 60 tax provisions in tax year 2025, including increases in the standard deduction for married couples and single individuals.
IRS increases special per diem rate for business travel
The special per diem rates that a taxpayer uses in travel and business expenses will be higher starting Oct. 1, as provided by the IRS.
Sec. 163(j) planning considerations
Businesses can explore several options to mitigate the interest deduction limitation under the Tax Cuts and Jobs Act.
Business standard mileage rate increases for 2024
The optional standard mileage rate for business use of a vehicle increased slightly from 2023. The new rate is effective Jan. 1.
IRS announces annual inflation adjustments for tax year 2024
The adjustments cover over 60 tax provisions and generally apply to tax returns that will be filed in 2025.
Substantiation of business expenses: A review of the basics
A recent Tax Court case highlights the fact that taxpayers bear the burden of substantiating not only the amount of the deduction but also that the purpose underlying the deduction is ordinary and necessary to operating their trade or business.
Tax Court rejects bad debt deductions
The Tax Courtβs opinion in Allen emphasizes the partiesβ conduct with respect to payments and contractual rights, along with a realistic view of the repayment expectations.
Special per diem rate for business travel rises
Starting Oct 1, 2023, the special per diem rates taxpayers may use to substantiate ordinary and necessary business expenses for travel away from home will go up, the IRS announced.
Long-awaited guidance provided for amortization of R&E expenditures
The IRS says taxpayers and tax professionals can rely on interim guidance under Sec. 174 for the amortization of research and experimental expenditures released on Friday in Notice 2023-63 until it issues proposed regulations based on the guidance, effective for tax years beginning in 2022.
Bad debt deductions from intrafamily advances
Loans within families can give rise to a loss deduction if not repaid, but this requires establishing, maintaining, and documenting a bona fide debtor-creditor relationship.
Mitigation of excess gain on inherited property
This item focuses on the rules to seek an adjustment: correcting excess gain on inherited property.
Is it a trade or business? Or a hobby or investment?
Many Code provisions apply only to a βtrade or business.β This article discusses the various tax consequences when an activity fails the relevant test and is instead deemed a hobby or investment.
Business standard mileage rate increases for 2023
The standard mileage rate for business use of a vehicle has increased, the IRS announced, effective as of Jan. 1.
Taxpayer marital status and the QBI deduction
This article provides an analysis in four scenarios of whether the QBI deduction will cause a marriage penalty or bonus and discusses whether the existence of a marriage penalty or bonus affects couplesβ decision to marry.
IRS raises per diem standard rates for business travel
Under Notice 2022-44, the high-low method rates will be slightly higher and the list of high-cost localities in the continental United States is revised, both effective Oct. 1.
employee benefits & pensions
Profits interests: The most tax-efficient equity grant to employees
By granting them a profits interest, entities taxed as partnerships can reward employees with equity. Mistakes, however, could cause challenges from taxing authorities.