SEC permits reasonable estimates in corporate tax reporting
Companies may initially have difficulty determining the effects of the new federal tax law on their income tax reporting.
Corporations
Safe harbor eliminates need for private letter ruling for some REIT and RIC distributions of stock and cash
The IRS established a safe harbor allowing distributions of stock to be treated as a distribution of property under Secs. 301 and 305(b) for publicly offered REITs or publicly owned RICs, as long as certain conditions are met.
Income from receipt of carbon sequestration credits relating to timberlands is qualifying REIT income
The IRS ruled it would consider income recognized by a REIT in connection with the receipt of carbon sequestration credits to be income qualifying the taxpayer to be a REIT.
IRS withdraws portions of Subchapter C nonrecognition rules
Treasury and the IRS withdrew parts of proposed net value regulations that would require an exchange of net value for transactions intended to qualify under Secs. 351 and 368 and a distribution of net value for transactions intended to qualify under Sec. 332.
When to use a tax-free reorganization
In some circumstances, a taxable stock sale may make more sense.
Items and factors to consider in setting reasonable compensation
All companies should maintain supporting documentation for payments.
Introducing U.S. equity crowdfunding: Potential risks and tax implications
New regulations issued by the SEC enable individual investors to invest in startup companies through equity crowdfunding.
How tax overhaul would change business taxes
The tax reform bill that Congress is expected to vote on this week contains numerous changes that will affect businesses large and small.
Congress passes tax reform
The House of Representatives reapproved tax reform legislation on Wednesday, sending the bill to President Donald Trump for his signature.
Senate passes tax reform bill; House must revote
The Senate voted early today in favor of the Tax Cuts and Jobs Act, H.R. 1, which the House of Representatives had approved Tuesday.
Leased farmland and the active business requirement for a tax-free reorganization
Meeting the active trade or business requirement is critical to ensuring a corporation leasing farmland qualifies for a tax-free divisive reorganization.
Substantive consolidation: A tale of two cases
Because there is no clear statutory guidance for how a bankruptcy judge determines if a trustee’s request to apply substantive consolidation should be granted, each case is different.
Reducing taxes with qualified patronage dividends
Cooperative corporations can shield net income from taxation by returning it to the patrons in the form of qualified patronage dividends.
IRS announces it will rule on tax-free stock distributions
The IRS is introducing an 18-month pilot program under which it will once again issue letter rulings concerning the general income tax effects of stock distributions under Sec. 355.
Flexible ownership incentives for key employees
To reward and retain key employees, companies often look for ways to extend ownership or the feeling of ownership.
Foreign income provisions in the Tax Cuts and Jobs Act
The House’s tax reform bill would make many changes to the taxation of US companies’ foreign subsidiaries.
House bill features many business tax changes
The House tax reform bill contains a large number of proposed changes that would affect businesses.
Phantom stock: Termination of right to buy or sell, treatment of asset and basis
The Tax Court considered whether redemption of phantom stock was a sale of a capital asset and what the tax basis in the redeemed phantom stock was.
Letter ruling provides guidance on distributions in a reorganization
The IRS ruled on how the distribution of stock is treated in a tax-free reorganization and whether there is any potential recognition of gain.
Recommendations for charitable contributions made by businesses
This column discusses the treatment and classification of contributions made by businesses.
