The IRS says it will again issue rulings on corporate leveraged spinoff transactions.
C Corporation Income Taxation
This item offers an overview of certain provisions in the regulations that could have state corporate income tax consequences.
The IRS could not recharacterize, under the substance-over-form doctrine, commissions paid by a DISC to two Roth IRAs as dividends..
This item presents an opportunity to minimize the tax impact of a distribution by a closely held corporation that is not made out of the corporation’s E&P.
This item focuses on stock redemptions, or transactions having the effect of a redemption, causing an ownership change.
The IRS is allowing calendar-year C corporations a six-month filing extension, instead of the five-month extension specified in the Code.
This column discusses examples of potential constructive dividends.
Taxpayers who have engaged in “micro-captive transactions,” which the Internal Revenue Service has designated as transactions of interest, have until May 1 to file the required disclosure statement.
The final regulations could provide opportunities for companies and industries that previously did not include expenditures for software developed primarily for their own internal use.
The proposed regulations are intended to further limit a corporation’s ability to separate business assets from nonbusiness assets in a tax-free manner.
Eligible small businesses can apply a portion of their research and development credit against their payroll tax liability, starting with 2016 tax years, under a new provision enacted in 2015.
In addition to extending bonus depreciation and phasing out the bonus rate, the PATH Act made several changes to the types of eligible property under Sec. 168(k)(2).
The IRS posted to its website confirmation that it is allowing calendar-year C corporations a six-month filing extension, despite statutory language that specifies a five-month extension for calendar-year C corporations.
Fifth Circuit vacated Tax Court’s decision that MoneyGram International Inc. was not a bank because the Tax Court applied incorrect definitions of “deposits” and “loans.”
Regulations settle much of the uncertainty for determining when software is developed for internal use.
Carrying over E&P from one entity to another and administrative burdens can lead to headaches down the road.
The tension between the two principles of the new regulations can cause taxpayers uncertainty.
This item provides a brief history of existing tax law in this area and IRS guidance and a summary of the recent developments.
A taxpayer was not entitled to defer gain on a disposition of property to a related party that met the Sec. 1031(a) requirements for a like-kind exchange.
Taxpayers should expect to see continued controversy regarding when a liability is fixed for customer discounts.