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Staying Informed in a Rapidly Evolving Policy Landscape

Success in implementing and executing a Total Tax Approach means that organizations must constantly monitor the rapidly changing tax legislative and regulatory landscape. Insights from a trusted advisor can help you develop plans and approaches to appropriately adapt to evolving tax environments and new complexities.  

We are committed to helping you navigate and thrive in this environment. Our team, which includes former Congressional, IRS, Treasury, and U.S. Tax Court staff, provides the latest analysis and insights to help you capitalize on tax planning opportunities. 

Let us be your primary resource for staying ahead in this complex regulatory tax policy environment.

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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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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

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 Extends Partnership Form 8308 Penalty Relief; Act by January 31

December 18, 2024
Article

IRS Extends Partnership Form 8308 Penalty Relief; Act by January 31

December 18, 2024

The IRS has issued guidance (Notice 2025-02) providing penalty relief for partnerships with unrealized receivables or inventory items that fail to furnish Form 8308, “Report of a Sale or Exchange of Certain Partnership Interests,” by January 31, 2025, to the transferor and transferee in certain partnership interest transfers that occurred in 2024.

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Article

Simplified Corrective Relief Recommended in Subchapter S ‘Double Fault’ Situations

December 18, 2024
Article

Simplified Corrective Relief Recommended in Subchapter S ‘Double Fault’ Situations

December 18, 2024

Recommendations submitted by the American Bar Association Section of Taxation (ABA Tax Section) suggest the Department of the Treasury and the IRS should expand the eligibility requirements for simplified corrective relief under Rev. Proc. 2022-19 to include what many refer to as “double fault” situations.

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Article

California FTB Sets Public Hearing Date for Proposed Market-Based Sourcing Regulations

December 16, 2024
Article

California FTB Sets Public Hearing Date for Proposed Market-Based Sourcing Regulations

December 16, 2024

The California Franchise Tax Board (FTB) has tentatively set a public hearing for January 25, 2025, to discuss proposed amendments to California’s market-based sourcing regulations.

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Article

Pennsylvania Reforms Its Tax Appeals Process

December 13, 2024
Article

Pennsylvania Reforms Its Tax Appeals Process

December 13, 2024

On October 29, Pennsylvania enacted S.B. 1051 to make important changes to its tax administrative appeals process. Taxpayers with Pennsylvania tax appeals should consider the bill’s implications for their cases and consider new opportunities to resolve tax disputes.

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The BDO Tax Strategist 2024 Webcast Series

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