Recent Chief Counsel Advice provides helpful insight to taxpayers planning or negotiating merger and acquisition transactions.
This item presents 10 ways that S corporations can lose their S election status, most of them involving trusts.
This item discusses the ability of a target in a Sec. 338(h)(10) transaction to use the safe-harbor election provided by Rev. Proc. 2011-29.
Taxing authorities have sought to incorporate adequate lead time into the tax filing process.
The potential effect of the built-in-gain tax is often a significant consideration during pending acquisitions involving an S corporation.
Restructuring an existing QSub in an attempt to qualify for an ordinary deduction is prohibited and might result in an unfavorable deferral of loss.
This column outlines the special considerations and issues related to life insurance policies for S Corporations.
Direct shareholder loans to an S corporation can be very important tools for tax planning.
The question of whether an S corporation should be treated the same as a C corporation when its subsidiary corporation is insolvent has not been definitively answered.
A recent Tax Court decision sheds light on the importance of lease terms to determine what is rent and how Sec. 467 may apply to advance rents.
This item provides an overview of the U.S. income tax implications of cancellation-of-debt income that results from bankruptcy or insolvency, with a focus on the differences in the tax treatment for C corporations, S corporations, and partnerships.
This item presents an overview of some of the tax points that should be kept in mind when choosing an entity.
IRS addressed whether an S corporation and its wholly owned subsidiary, a QSub, must prorate annual income following a midyear voluntary revocation of subchapter S election.
S corporations and their shareholders often engage in transactions in which they transfer property with a basis greater than its FMV. This article examines the tax effects on both shareholders and the corporation.
The IRS issued final regulations addressing the basis of indebtedness of S corporations to their shareholders.
This item describes eligible shareholder trusts and the elections they must make.
When consulting on S corporation asset sales or sales treated as asset sales from a tax perspective, tax practitioners need to be aware that different tax consequences than expected can sometimes result under the installment sale rules of Sec. 453.
If a qualified subchapter S trust (QSST) owns both S corporation stock and other assets, determining whether the income from the other assets must be distributed to the beneficiary depends on the terms of the trust document.
While the Seventh Circuit's decision in Vainisi was favorable for S corporation banks investing in tax-exempt obligations, those banks nonetheless must pay close attention to the specific type of tax-exempt obligations they purchase if they expect to reap the benefits of that decision.
Some unique issues can arise when computing the domestic production activities deduction for a passthrough entity.