Corporate Income Tax news
Corporate income tax developments from around the world, including rate changes, incentives, anti-avoidance rules, tax authority guidance and court rulings, collected from the tax authorities, advisers and publishers AskColm monitors and updated daily.
341 articles in the archive, showing the latest 50.
You’re Going the Wrong Way!
A Tax Notes piece by University of Michigan law professor Reuven Avi-Yonah questions proposals to force large private businesses to convert to C corporations, examining what policy goals such a move would actually achieve. The piece challenges the fiscal illusion…
Bloomberg: Ireland Plans More Changes to R&D Tax Credit, IP Incentives
Ireland plans to expand its R&D tax credit and extend refunds on intellectual property profits as part of its October budget. Finance Minister Simon Harris also announced changes to withholding taxes and committed to further implementation measures.
SaaS Subscription Fee Is Not “Royalty” Merely Because Technology Does the Work
ITAT Mumbai has ruled that SaaS subscription fees do not constitute 'royalty' simply because technology performs the underlying work. The tribunal held that access to a communication platform does not amount to use of a 'process' under Section 9(1)(vi) of…
Calcutta HC Dismisses Revenue’s Appeal Against ITAT’s Deletion of Rs. 11.35 Cr Addition
The Calcutta High Court dismissed the revenue department's appeal against an ITAT order that deleted a Rs. 11.35 crore income tax addition made against businessman Suresh Kumar Banthia for assessment year 2020-21. The Division Bench noted that while strict rules…
Agency Information Collection Activities: Comment Request on the Burden Related to Excise Tax on Repurchase of Corporate Stock
The IRS is inviting public comments under the Paperwork Reduction Act on the information collection burden related to the excise tax on corporate stock repurchases.
Section 351 Exchanges and ETFs
The IRS issued Rev. Rul. 2026-20 targeting the use of Section 351 exchanges in the context of ETFs, specifically addressing so-called 'heartbeat' transactions. These transactions exploit ETFs' status as regulated investment companies under the tax code. The ruling signals IRS…
Corporate tax update – October 2026
Saffery's October 2026 corporate tax update covers key developments for businesses in the UK, including HMRC activity, policy changes, and recent case law, with practical guidance on where businesses may need to take action.
HMRC large business compliance 2026: what the government’s response means for businesses
The UK government has accepted all seven recommendations from the Public Accounts Committee following its review of HMRC's large business tax compliance approach. The government's response endorses HMRC's compliance strategy while calling for further reform, with implications for how large…
Why AI is reshaping tax risks for India’s GCCs
Global capability centres using artificial intelligence to deliver services are exposing multinational enterprises to new risks around permanent establishment and transfer pricing, as existing compliance frameworks prove inadequate for the challenges AI presents.
Linklaters to Paul Wurth: changing contours of India’s force of attraction rule
Legal experts from Lakshmikumaran & Sridharan analyse how the Paul Wurth ruling could affect the application of India's force of attraction rule and the attribution of profits under Indian tax treaties.
California Refundable Credit Election May Create Planning Opportunity for Businesses Limited by the $5 Million Credit Cap | | Andersen
California businesses subject to the $5 million credit cap may have a planning opportunity through a refundable credit election. The election could allow businesses to recover credits that would otherwise be limited, offering a potential tax benefit for qualifying entities.
Novel Strategy Prompted ETF Guidance, Treasury Atty Says
A US Treasury official has said that recent guidance cracking down on improper use of exchange-traded fund conversions was prompted by a marketed transaction that existing rules targeting abusive practices did not directly address. The guidance took the form of…
Philippine Airlines Asks Tax Court To Cut $5.7M Off Tax Bill
Philippine Airlines has asked the US Tax Court to reduce its tax bill by more than $5.7 million of a $7.1 million assessment. The airline argues that the IRS cannot deny it a tax exemption on income from passengers and…
Selling Your Business? The Tax Differences Between Selling Shares and Selling Assets for Canadians
Canadians selling a business face different tax outcomes depending on whether they sell shares or assets. Key considerations include the Lifetime Capital Gains Exemption, capital cost allowance recapture and the allocation of liability risks between buyer and seller.
Sen. Tim Scott Touts Federal Film Tax Credit as a Blue-Collar Jobs Bill
A bipartisan bill proposing a federal film tax credit is being championed in the US Senate by Senator Tim Scott, a South Carolina Republican, alongside Senator Adam Schiff of California. A separate bipartisan coalition is advancing a parallel measure in…
Swiss Corporate Tax Insights
Tax Partner AG has contributed the Switzerland chapter to the Corporate Tax & Tax Controversy Comparative Guide 2026, published by The Global Legal Post as part of its Law Over Borders series.
Sweden Updates Tax Treaties
Sweden has signed a new tax treaty with the Netherlands and protocols amending its existing treaties with Ireland and Cyprus. The changes are part of a broader effort to modernise cross-border tax rules and strengthen anti-abuse measures.
Luxembourg Simplifies Pillar Two
Luxembourg has proposed amendments to its Pillar Two legislation to implement the OECD's new side-by-side solution, along with a range of new safe harbours and simplification measures.
Meta’s Outlandish Tax Breaks for AI Data Centers
Meta is using the research tax credit, a relief designed to encourage innovation, to cover the cost of equipment in its AI data centres. According to ITEP, Meta paid just 3.5% of its profits in federal corporate income taxes in…
3rd Circ. Probes Payment Recipients In Fund's $100M Tax Row
A Third Circuit panel has examined the accounting rules governing dealer-and-customer transactions to determine whether the IRS was correct to issue a $100 million tax bill against a Cayman Islands hedge fund over payments connected to US portfolio companies.
La estabilidad o invariabilidad tributaria: su aplicación para favorecer las inversiones en AL
This article, published in Spanish, discusses tax stability and invariability in the context of Latin American investment, noting that taxation is subject to each country's economic and social policy and requires ongoing adaptation through reforms.
Proposed Regulations Offer a Narrow Escape Hatch for Entities That Inadvertently Self-Certified as a QOF
Proposed regulations would allow an entity that accidentally self-certified as a Qualified Opportunity Fund by filing a Form 8996 in error to revoke that election. Previously, such a mistaken filing attached to an entity indefinitely. The relief is narrow: revocation…
Why Expensing New Rental Housing Is One of the Best Ways to Tackle the Housing Supply Problem
The Tax Foundation examines the housing supply shortage in the United States and considers policy solutions, focusing on the case for allowing full expensing of new residential rental structures as a way to increase housing supply.
Federal Bill Takes Aim at MSO/Friendly-PC Structures: The Tax Implications
A proposed federal bill, the Stop Corporate Takeovers of Physicians Act of 2026, could affect the management services organisation and friendly PC structures commonly used in physician practice investments. The bill has been referred to the House Energy and Commerce…
Where the Rubber Meets the Road: What Return-to-Provision Reveals About Your Tax Function
Finance and tax leaders should not treat the filing of income tax returns as separate from financial reporting or as a purely end-of-year exercise, according to Withum. The return-to-provision process can reveal important information about the effectiveness of a tax…
Botched Application Costs Zipper Co. $20M Tax Break
A Georgia appeals court has rejected a zipper manufacturer's attempt to overturn a county tax board ruling that awarded it a roughly $40 million tax exemption rather than the $60 million it sought. The court found that the company's failure…
Tax Court Approves Penalties On Captive Without Substance
The US Tax Court has upheld IRS penalties against policyholders of a California company's captive insurance arrangement, which the IRS determined lacked economic substance. The court found that the policyholders failed to report the transactions in their 2015 tax returns.
Foreign Tax Advantages after the Tax Cuts and Jobs Act
Researchers from the University of Minnesota have published a working paper examining the effects of the Tax Cuts and Jobs Act on foreign tax advantages for US public companies. The study uses a firm-year panel of income-tax rate reconciliations drawn…
CRS Exposes the Parity Gap
A Congressional Research Service report provides new analysis supporting the case that the Section 199A deduction is necessary to keep pass-through businesses competitive with C corporations. The report looks at the potential effects of raising the Section 199A deduction from…
Evaluating Treasury’s Proposed Nondiscrimination Regs
The IRS and Treasury have released proposed regulations on racial nondiscrimination in private institutions, designated REG-119986-25, under the Bob Jones framework. A piece by Marie Sapirie in Tax Notes evaluates the proposed rules.
Tax Audit & ITR Due Dates Extended: CBDT Gives 21-Day Relief for AY 2026–27
India's Central Board of Direct Taxes has extended the deadlines for tax audit reports and income tax returns for the 2026-27 assessment year, giving taxpayers and professionals an additional 21 days.
CBDT Extends Tax Audit Report Due Date to 21st October 2026
The Finance Ministry has extended the tax audit report deadline for AY 2026-27 from 30 September to 21 October 2026. The extension follows representations made by tax professionals and business associations. An official notification has been released.
AICPA Requests Modifications to Interim CAMT Guidance Application for Financially Troubled Companies
The AICPA has requested modifications to interim guidance on the Corporate Alternative Minimum Tax, which covers its application to domestic corporate transactions, financially troubled companies, and tax consolidated groups.
Repetti Presents “How Our Tax Laws Aid Private Equity Investments in Hospitals and Nursing Homes” Today at Northwestern
James Repetti is presenting a paper at Northwestern's Advanced Topics in Taxation Colloquium examining how tax laws support private equity investment in hospitals and nursing homes, noting that the social welfare impact of private equity funds across different sectors of…
Autumn Budget 2026: expected UK tax changes and what businesses and individuals should do now
Saffery has published guidance on the Autumn Budget 2026, setting out what businesses, entrepreneurs and families need to know about possible tax changes and government commitments, and what steps they should consider taking now.
Dryda et al.: Global Ripple Effects of Corporate Tax Reforms
A working paper published by the National Bureau of Economic Research examines how corporate tax reforms in one country affect others within a fragmented global tax regime. The study, by economists from the University of Toronto and Michigan State University,…
Poland Moves to Remove Income-Tax Penalties Linked to VAT White-List and Split-Payment Errors
Poland is advancing legislation to remove income tax penalties that arise from errors related to the VAT white-list of taxpayers and the split-payment mechanism. Currently, businesses that inadvertently pay suppliers not listed on the white-list or misuse split-payment accounts face…
Experts explore latest federal guidance, state tax divergence
Grant Thornton tax specialists used a September webinar to examine recent federal tax, trade and administrative developments, emphasising that for many companies the greater challenge lies in planning and financial reporting consequences rather than understanding the rules themselves.
Australia Broadens Application of Software Royalties Treatment
Australia's Tax Office has issued new guidance that widens the range of circumstances in which cross-border software payments can be classified as royalties, making them subject to withholding tax.
Canada Unveils Mega Deduction for Investment
Canada's federal government has proposed a Productivity Mega Deduction that would allow businesses to immediately deduct the full cost of eligible capital investments. Under the current system, tax relief on such investments is claimed gradually over several years. The new…
Hollywood Would Get 20% Federal Film Tax Credit Under Proposed New Bill
A proposed US bill, the Motion Picture, Television and Entertainment Revitalization Act, would introduce a 20% federal tax credit on US labour costs for film and television productions, covering post-production and visual effects work.
Weighing the risk: US tax reforms driving MNEs to reassess IP models
Deloitte professionals examine how changes to US tax law are prompting multinational enterprises to reconsider intellectual property and operating models centred on the US, and how European tax authorities are responding to those shifts.
Germany Clarifies Cross-Border Interest Rules
Germany's Federal Tax Court has ruled that interest payments connected to a Dutch group structure can be denied as a tax deduction in Germany under Section 4i of the Income Tax Act.
Permanent Establishment Risk in the Philippines: Why Outsourcing and EOR Do Not Eliminate Tax Exposure
Foreign enterprises operating in the Philippines through outsourcing providers or employer of record arrangements may still be exposed to permanent establishment risk and the associated tax liabilities, as these structures do not automatically eliminate tax exposure.
Tax banks more, now!
An opinion piece arguing that banks should face higher taxation, likely in response to perceived excess profits or systemic advantages enjoyed by the financial sector. The article advocates for increased tax burdens on banking institutions, touching on corporate tax policy…
8th Circ. Asked To Nix Fraud Tax Credit Suit, $90M Judgment
A man accused of helping set up a sham limited liability company that fraudulently obtained millions in alternative fuel mixture tax credits has asked the Eighth Circuit to reverse a judgment of more than $90 million against him, arguing he…
Interest Deductibility Limitations and Corporate Innovation
This article examines the relationship between interest deductibility limitations and corporate innovation activity. Interest deductibility rules, such as earnings-stripping provisions and thin-capitalization constraints, affect how companies finance research and development investments. Restrictions on deducting interest expenses can raise the cost…
California updates IRC conformity provisions
California has updated its Internal Revenue Code conformity provisions, aligning state tax law with federal IRC rules. California is a selective conformity state, meaning it does not automatically adopt federal tax changes and must explicitly enact conformity legislation. This update…
Representation for extension of the specified date for furnishing Tax Audit Reports u/s 44AB and other audit reports for AY 2026-27 from 30 September 2026 to 31 October 2026, and of the return due date in audit cases from 31 October 2026 to 30 November 2026
A formal representation has been submitted requesting an extension of the deadline for filing Tax Audit Reports under Section 44AB of the Income Tax Act for Assessment Year 2026-27. The request seeks to push the tax audit report due date…
Year-End Tax Planning for Businesses: What Should Be on Your Radar Now?
This article from Withum covers year-end tax planning considerations for businesses, addressing key areas such as depreciation, deductions, entity structure, and other tax optimization strategies businesses should evaluate before the close of the tax year. It provides practical guidance on…