C Corporation Income Taxation

IRS releases final rules on business meals and entertainment

The IRS finalized rules implementing provisions of the law known as the Tax Cuts and Jobs Act, disallowing deductions for most business entertainment expenses and distinguishing them from business food and beverage expenses that remain deductible.

IRS issues more rules on GILTI tax

The IRS issued final regulations under the GILTI rules on the treatment of income subject to a high rate of foreign tax. At the same time, the IRS issued proposed rules conforming the GILTI high-tax exception rules with the Subpart F high-tax exception.

Legal entity rationalization and simplification

The process of a legal entity rationalization or simplification of a legal organizational chart has numerous moving and interrelated components that need to be considered during each step of the process.

Private equity and F reorganizations involving S corporations

The M&A market is poised to regain its pre-COVID-19 activity levels as many business owners seek to exit closely held businesses or explore alternatives. One popular transaction that could emerge is Sec. 368(a)(1)(F) reorganizations F reorganizations) of S corporations.

Disallowed transportation fringe benefit rules proposed

The IRS issued proposed regulations implementing changes to Sec. 274 that disallow a deduction for the expense of any Sec. 132(f) qualified transportation fringe provided to an employee, effective for amounts paid or incurred after Dec. 31, 2017.

Incorporating a single-owner business

Single-member LLCs and sole proprietorships must consider several unique issues when choosing to incorporate — including the tax consequences of transferring, or not transferring, assets into the newly formed corporation.

Mergers and acquisitions during the COVID-19 pandemic

A host of new issues have arisen in merger-and-acquisition transactions because of the unpredictable business environment caused by changes in the law in response to the COVID-19 pandemic. This article discusses some of the pandemic-related concerns buyers and sellers will have in M&A transactions, and the additional safeguards and procedures participants should take to deal with these concerns.

Newsletter Articles

50th ANNIVERSARY

50 years of The Tax Adviser

The January 2020 issue marks the 50th anniversary of The Tax Adviser, which was first published in January 1970. Over the coming year, we will be looking back at early issues of the magazine, highlighting interesting tidbits.

TAX RELIEF

Quirks spurred by COVID-19 tax relief

This article discusses some procedural and administrative quirks that have emerged with the new tax legislative, regulatory, and procedural guidance related to COVID-19.