On September 9, 2019, the Treasury Department (“Treasury”) and the Internal Revenue Service (the IRS) issued proposed section 382 regulations (REG-125710-18) (the “Proposed Regulations”) reversing ...

I’ve discussed the changes to IRC Section 174 at length in previous articles, warning about the TCJA’s change to research and experimental costs under 174, as well as the IRS finally providing some ...

California requires taxpayers that have income within and outside the state to "apportion" their overall income between the two categories based upon certain factors and rules for determining their ...