About "Washington national tax services (WNTS)"

The PwC Washington National Tax Services (WNTS) group helps companies stay up-to-date on the latest legislative and regulatory matters and navigate the ever-changing tax landscape.

Article archive

• Final regulations on deemed asset sale elections offer taxpayers more flexibility
  

  5/21/13 | Washington national tax services (WNTS)

  The IRS published final regulations which permits taxpayers to elect to treat certain dispositions of a target corporation’s stock as a sale of the underlying assets of the target corporation.

• Webcast

  Accounting methods considerations for M&A transactions webcast – June 12, 2013
  

  5/16/13 | Washington national tax services (WNTS)

  Members of PwC's Washington National Tax practice will lead an hour-long webcast that includes a discussion of common M&A transactions and the potential accounting method considerations that may result.

• IRS issues safe harbor ‘repairs’ guidance for electric generation
  

  5/10/13 | Washington national tax services (WNTS)

  The IRS recently issued Rev. Proc. 2013-24, which provides safe harbor definitions of units of property and major components that taxpayers may use in determining whether expenditures to maintain, replace, or improve steam or electric power generation property must be capitalized under Section 263(a).  

• Numerous business tax reform proposals included in report to Ways and Means Committee
  

  5/9/13 | Washington national tax services (WNTS)

  The House Ways and Means Committee May 8 held a meeting covering the work of certain of its 11 bipartisan working groups on tax reform.

• IRS issues favorable guidance on certain transaction costs
  

  5/7/13 | Washington national tax services (WNTS)

  LB&I recently issued a memorandum for all staff regarding the treatment of eligible milestone payments paid or incurred in the course of certain transactions.

• Joint Tax Committee staff issues report on Ways and Means tax reform working groups
  

  5/6/13 | Washington national tax services (WNTS)

  JCT staff today issued a 568-page report on "Present Law and Suggestions for Reform Submitted to the Tax Reform Working Groups."

• Obama Administration FY 2014 budget focuses on tax reform, deficit reduction, and new initiatives
  

  4/10/13 | Washington national tax services (WNTS)

  The President's budget asks Congress to "immediately begin the process of reforming the individual and business tax systems."

• Taxpayers may continue to accelerate certain AMT credits
  

  4/2/13 | Washington national tax services (WNTS)

  Corporations or consolidated groups with alternative minimum tax (AMT) credits from pre-2006 tax years may continue to accelerate use of these credits instead of claiming Section 168(k) additional bonus depreciation for eligible qualified property.

• Senate Budget Committee calls for tax increase; Senate Finance Committee prepares for tax reform
  

  3/14/13 | Washington national tax services (WNTS)

  The Senate Budget Committee on a party-line vote approved an FY 2014 budget resolution. Senate Finance Committee announced upcoming meetings.

• House Republican budget calls for business and individual tax reform
  

  3/12/13 | Washington national tax services (WNTS)

  House Budget Committee Chairman Paul Ryan (R-WI) today released a proposed FY 2014 House budget resolution.

• House Ways and Means Committee releases pass-through tax reform discussion draft
  

  3/12/13 | Washington national tax services (WNTS)

  House Ways and Means issued a 'small business' tax reform discussion draft that features proposals affecting large and small partnerships and S corporations.

• OECD "base erosion and profit shifting" report looks to action plan
  

  2/12/13 | Washington national tax services (WNTS)

  The OECD released a related 90-page report, Addressing Base Erosion and Profit Shifting.

• Challenges ahead for tax policy - 2013 Tax Legislative Outlook
  

  1/31/13 | Washington national tax services (WNTS)

  PwC's Washington National Tax Services (WNTS) offers a preview of the key tax policy issues facing the Obama Administration and Congress in 2013, including the outlook for comprehensive tax reform, deficit reduction, business tax provisions that expire at the end of 2013, and other tax policy matters of importance to today's business leaders.

• Final FATCA regulations issued: Let the compliance begin
  

  1/21/13 | Washington national tax services (WNTS)

  Final regulations for Foreign Account Tax Compliance Act (FATCA) were issued on January 17, 2013. FATCA was enacted as part of the Hiring Incentives to Restore Employment Act (HIRE Act) on March 18, 2010 to serve as an administrative tool to prevent and detect US tax evasion and improve taxpayer compliance. The final regulations contain over 500 pages of guidance.

• Fiscal cliff legislation extends research credit, resolves M&A-related credit issue
  

  1/8/13 | Washington national tax services (WNTS)

  American Taxpayer Relief Act of 2012 extends the research credit for two years and resolves an issue regarding the treatment of qualified research expenditures. Read WNTS Insight fo rmore details.

• New tax law extends business tax incentives
  

  1/5/13 | Washington national tax services (WNTS)

  President Barack Obama on January 2 signed into law the "American Taxpayer Relief Act of 2012", which includes permanent extensions of certain 2001 and 2003 tax provisions for individuals with incomes below $400,000, and joint filers with incomes below $450,000.

• Congress passes fiscal cliff agreement to extend tax rates for incomes below $450,000; deal includes business "tax extenders"
  

  1/1/13 | Washington national tax services (WNTS)

  The President recently signed a fiscal cliff agreement that extended certain tax rates for incomes below $450,000 and included several business "tax extenders." Read WNTS Insight for more details.

• 2012 election results point to continued divisions over tax policy
  

  11/7/12 | Washington national tax services (WNTS)

  Can compromises be reached before the end of this year to avoid the 'fiscal cliff' effect of scheduled tax increases and spending reductions?

• Top automatic accounting method changes for 2011 returns
  

  8/27/12 | Washington national tax services (WNTS)

  Differing considerations may affect taxpayer decisions on accounting method changes. For example, taxpayers seeking to increase cash flow and decrease their current cash tax liability may benefit from accounting method changes that accelerate deductions or defer revenue. At the same time, because of the increased IRS focus on uncertain tax positions, taxpayers also may want to file accounting method changes to correct improper methods of accounting and obtain audit protection.

• IRS issues important guidance on expense reimbursement arrangements
  

  8/8/12 | Washington national tax services (WNTS)

  The IRS recently issued proposed regulations explaining the exception to the 50-percent deduction limitation of section 274(n) that applies with respect to certain expenditures paid or incurred under a reimbursement or other expense allowance arrangement. The rules in the proposed regulations (subject to any changes when finalized) can be very important for taxpayers that enter into reimbursement arrangements with their clients or customers for expenses that are subject to the 50-percent limitation of section 274(n).

• IRS releases important guidance on personal use of business aircraft
  

  8/6/12 | Washington national tax services (WNTS)

  The IRS on July 31 issued final regulations on the tax treatment of an employer with respect to certain personal use of employer-provided aircraft. The final regulations apply to tax years beginning after August 1, 2012.

• IRS challenges certain cross-border reorganizations involving intangibles
  

  8/1/12 | Washington national tax services (WNTS)

  Notice 2012-39, recently issued by the IRS, provides guidance regarding the treatment under section 367(d) of transactions that, according to the IRS, raise "significant policy concerns" involving transfers of intangible property by a domestic corporation to a foreign corporation in certain corporate reorganizations. For more, read this WNTS insight.

• Federal Circuit invalidates interest capitalization "associated property rule" when applied to temporarily withdrawn property
  

  7/17/12 | Washington national tax services (WNTS)

  In Dominion Resources, Inc. v. United States, the U.S. Court of Appeals for the Federal Circuit, reversing the Court of Federal Claims, held that the "associated property rule" -- when applied to property temporarily withdrawn from service -- is invalid because it is not a reasonable interpretation of section 263A(f). For more, read this WNTS insight.

• Final foreign tax credit regulations on overall domestic losses and overall foreign losses provide certainty, flexibility
  

  6/29/12 | Washington national tax services (WNTS)

  The IRS recently issued final regulations under sections 904(f) and (g) that implement the overall domestic loss (ODL) regime enacted in the American Jobs Creation Act of 2004. The regulations also provide updates that reflect statutory amendments to the overall foreign loss (OFL) rules enacted since 1986.

• Supreme Court upholds health care law; tax provisions remain in place
  

  6/28/12 | Washington national tax services (WNTS)

  The U.S. Supreme Court today issued its decision on the "Patient Protection and Affordable Care Act" and the related Reconciliation Act of 2010. In a five to four decision, the Court ruled that the ACA's mandate for individuals to purchase health insurance is constitutional under the taxing power of Congress.

• OECD releases highly anticipated draft of intangibles transfer pricing guidelines
  

  6/22/12 | Washington national tax services (WNTS)

  The OECD on June 6 published the first public Discussion Draft of its revision of Chapter VI, Special Considerations for Intangible Property, of the OECD Transfer Pricing Guidelines. The Discussion Draft addresses numerous issues; this WNTS Insight focuses on some of the most important.

• Claims Court: Transfer pricing regulations bar amended return that would reduce taxable income
  

  6/5/12 | Washington national tax services (WNTS)

  Citing the "plain meaning" of one provision of the section 482 transfer pricing regulations, the U.S. Court of Federal Claims has held that the regulations prohibit a taxpayer from making any changes to the computation of transfer prices on an amended return if those changes would reduce the taxpayer's taxable income. The taxpayer, Intersport Fashions West (Intersport), has appealed the decision to the U.S. Court of Appeals for the Federal Circuit.

• IRS LB&I Division to realign domestic operations for greater efficiency
  

  5/29/12 | Washington national tax services (WNTS)

  The Commissioner of the IRS Large Business and International Division (LB&I) announced a partial realignment of LB&I domestic operations. The goal of the realignment is to make the division more agile, efficient, and consistent in its ongoing operations. The realignment is expected to take several months to complete, and will take effect on October 1, 2012, the start of the IRS's next fiscal year.

• IRS rules favorably on key bonus depreciation issue
  

  5/14/12 | Washington national tax services (WNTS)

  In a recently issued private letter ruling (PLR 201214003), the IRS concluded that certain self-constructed property qualifies for the 50-percent additional first-year depreciation deduction (bonus depreciation) under section 168(k)(1) and that some components of the property may qualify for 100-percent bonus depreciation if a proper election is made.

• Supreme Court upholds restrictive view of six-year tax assessment provision
  

  4/25/12 | Washington national tax services (WNTS)

  By a 5-4 vote without a clear majority opinion, the U.S. Supreme Court today held that the overstatement of basis of an asset does not give rise to an omission of gross income for purposes of establishing a six-year period of limitations for assessment. In so doing, the Court placed a restriction on last year's opinion in Mayo Foundation for Medical Education and Research v. United States.

• IRS increases scrutiny of compliance with executive compensation deduction limit
  

  3/22/12 | Washington national tax services (WNTS)

  Continuing recent trends toward increased scrutiny of executive compensation, the IRS has stepped up its audit activity with respect to the $1 million annual deduction limitation on certain compensation paid to "covered employees" of publicly held corporations under Code section 162(m), as well as taxpayer compliance with the requirements for nonqualified deferred compensation arrangements under section 409A.