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California Legislature Recommends Updating Conformity to Select IRC Provisions

December 19, 2024
Article

California Legislature Recommends Updating Conformity to Select IRC Provisions

December 19, 2024

The California Senate Revenue and Taxation Committee has released its 2024 tax conformity recommendations on whether California should conform to various changes made to the Internal Revenue Code after January 1, 2015 (known as “selective conformity”).

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Article

IRS Releases Guidance on New Transfer Pricing Methodology

December 19, 2024
Article

IRS Releases Guidance on New Transfer Pricing Methodology

December 19, 2024

After years of debate and negotiation, the Organization for Economic Cooperation and Development’s (OECD’s) Pillar One, Amount B has taken a major step forward with the IRS’s release on December 18, 2024, of Notice 2025-04: “Application of the Simplified and Streamlined Approach under Section 482.”

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Article

Treasury, IRS Issue Section 987 Regulations on Foreign Currency Gain or Losses

December 19, 2024
Article

Treasury, IRS Issue Section 987 Regulations on Foreign Currency Gain or Losses

December 19, 2024

The U.S Treasury Department and the IRS on December 10, 2024, issued final and proposed regulations under Internal Revenue Code Section 987. The Section 987 regulations provide guidance for determining taxable income or loss or earnings and profits of a taxpayer with respect to a qualified business unit (QBU) that uses a different functional currency than its owner.

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Article

IRS Updates Procedural Guidance on Section 174 Accounting Method Changes for Taxable Years Beginning in 2024

December 19, 2024
Article

IRS Updates Procedural Guidance on Section 174 Accounting Method Changes for Taxable Years Beginning in 2024

December 19, 2024

Rev. Proc. 2025-8, issued on December 17, 2024, provides modified procedural guidance that expands the ability of taxpayers with taxable years beginning in 2024 to file an automatic accounting method change for specified research or experimental expenditures (SREs) under Internal Revenue Code Section 174.

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