Leasing property to a corporation
Shareholders can reap several benefits by leasing property to their corporation instead of transferring ownership to the company.
Corporations
Timing of the tax deduction for worthless intangibles
The challenge taxpayers frequently face is determining the date of sale, abandonment, or worthlessness.
LB&I campaigns update
The IRS’s LB&I division implemented a major restructuring intended to make better use of IRS resources.
IRS provides initial guidance on new Sec. 162(m)
The IRS issued guidance regarding amended Sec. 162(m), which limits the allowable deduction for remuneration paid by any publicly held corporation to a covered employee to $1 million.
Ninth Circuit withdraws Altera opinion
The order announcing the withdrawal says it is being done “to allow time for the reconstituted panel to confer on this appeal.”
Foreign-derived intangible income deduction: Tax reform’s overlooked new benefit for U.S. corporate exporters
One new opportunity created by the TCJA is the foreign-derived intangible income deduction in Sec. 250(a).
Proposed regs. address several transition tax issues
The IRS issued proposed regulations on the Sec. 965 transition tax that requires U.S. shareholders of deferred foreign income corporations to pay tax on post-1986 deferred income.
The carrot-and-stick approach to on-shoring intangible value
This item discusses provisions of the TCJA that seek to curb the erosion of the U.S. tax base.
Updates to Sec. 382 NUBIG and NUBIL safe harbors
With the increased use of stock acquisitions, buyers must correctly apply the Sec. 382 limitations, including the additional analysis to determine the impact of NUBIG and NUBIL.
Another look at C corp. vs. S corp. in light of tax reform
In the typical closely held business context, the TCJA’s reduction of corporate tax rates to a flat 21% is far from a panacea.
Stock-based compensation cost-sharing regs. valid
The Ninth Circuit reversed a Tax Court decision invalidating a cost-sharing regulation that requires allocation of stock-based compensation costs between related parties.
Equitable recoupment applies to employment taxes of law firm
A successor law firm was given credit for the employment tax payments of its predecessor under the doctrine of equitable recoupment.
Applying the rescission doctrine to dividend distributions: A practical guide
This discussion provides insight into planning opportunities to avoid the trap of unwinding a dividend.
Amended Sec. 965 may provide a Sec. 382 benefit: Deemed repatriation and RBIG
This item explores whether the toll charge might be treated as a recognized built-in gain under Sec. 382(h).
Federal tax reform: Not so encouraging for state and local incentives
Some incentives used by state and local governments to attract corporations will now likely be income to the recipient corporation.
How the 2017 tax overhaul changed Sec. 162(m)
This article discusses how the TCJA altered corporations’ responsibilities and the potential compensation implications.
Diesel particulate filters: Taxation and credits
This discussion focuses on the federal excise tax treatment of DPFs and potential fuel tax credits that may be claimed for fuel used to operate DPFs.
Tax treatment of individual owners of bitcoin and other virtual currencies held for personal use or investment
Tax preparers will need to be proactive in helping their clients identify and report any potentially taxable transactions.
IRS issues first guidance on new business interest limitation
The IRS issues guidance on business interest limitation under the new tax act.
Code’s plain language prevails, despite anomalies
The owner of a hotel and restaurant complex was not entitled to capital gains treatment under Sec. 1234A for a deposit it retained after a would-be buyer terminated a contract to purchase the complex.
