Elite engineers’ soaring compensation packages are complicating R&D tax credit claims under IRC §41, requiring companies to enhance their audit readiness with more rigorous documentation of qualified research activities.
Imputed underpayments under the Bipartisan Budget Act of 2015 are often unexpectedly high due to the inclusion of non-income items in calculations, affecting partnerships during audits and Administrative Adjustment Requests.
The DOJ Tax Division’s dissolution necessitates a post-mortem of the IRS-DOJ partnership to identify the critical elements for U.S. tax enforcement and voluntary compliance.
HR solutions can create unexpected tax liabilities, requiring cross-functional vigilance and proactive strategies to ensure compliance.
AI’s integration into software development challenges traditional R&D tax credit criteria, necessitating new frameworks for eligibility.
Key tax cases in 2026 will address economic substance, limited partnerships’ distributive shares in calculating self-employment tax, and the nondelegation doctrine related to executive authority.
State trust income tax nexus rules vary widely, requiring regular review to minimize tax exposure as courts increasingly reject perpetual nexus claims.
Advising content creators requires specialized strategies to address unique priorities, assets, and income streams.
The 2025 tax law’s interest expense limitation changes may require companies to reexamine deferred tax asset valuation allowance assessments with possible impacts to naked credits.
This is Bloomberg Tax’s roundup of the top five business Tax Management Memorandum articles of 2025.
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