“Companies that previously said ‘Oh I don’t have to worry about this, I didn’t do R&D and never claim the credit’ now have to take it into consideration. Now almost every company has to start thinking about it.”
Managing Director Kevin M. Jacobs speaks with CFO Dive on two provisions of the 2017 Tax Cuts and Jobs Act that went into effect last year that are causing finance leaders some headaches.
Changes were made to Sec. 163(j) of the tax code to lower how much interest expense a company can deduct by shifting the calculation of the net business interest expense deduction to 30% of earnings before interest and taxes, rather than before interest, taxes, depreciation and amortization.
The biggest change was that made to Sec. 174 of the tax code which shifted how research and experimental expenditures are calculated: money spent on developing products can no longer be immediately deducted but must be capitalized and amortized over a handful of years, with the period over which that happens tied to whether the work is done in or outside the U.S.
Read the Full Article
Limited Partners! Part Deux: The Fifth Circuit Rewrites the LP Rules … Again
August 19, 2026
The Fifth Circuit has replaced its prior opinion in K Alain, L.L.L.P. v. Commissioner, adopting a new framework for determining when limited partners qualify for the self-employment tax exception.
India Tax Alert | Gujarat High Court Landmark Ruling on Corporate Guarantees
August 17, 2026
The recent Gujarat High Court ruling in Torrent Power Ltd. v. Union of India & Ors. is a significant development on the GST treatment of corporate guarantees between related persons .
USCIT Upholds IEEPA Suspension of De Minimis Treatment in Axle of Dearborn
August 13, 2026
A three-judge panel of the U.S. Court of International Trade held that IEEPA authorizes the President to suspend the Section 321 de minimis privilege worldwide — even though, under Learning Resources, IEEPA does not authorize the President to impose tariffs.
What U.S.-Headquartered Multinationals Must Get Right in Europe and Australia
August 12, 2026
In this new article originally published on Tax Notes International, July 20, 2026, Andrea Groiß, Janita Bach, and Alexander Hofmann explain what organizations need to get right, from understanding reporting obligations to establishing robust processes that support both compliance and stakeholder confidence.
