IRS to 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.
Corporations
Deducting startup and expansion costs
Certain business expenses incurred to start or expand a business can be currently deducted.
Tax Court allows full meal deduction for NHL team’s away games
Pregame meals provided to Boston Bruins players and personnel before away games qualify as a de minimis fringe benefit.
IRS will rule on leveraged spinoffs again
The IRS says it will again issue rulings on corporate leveraged spinoff transactions.
Will tax reform make C corps. more attractive for closely held businesses?
Tax reform is expected to reduce the tax rates imposed on C corporations’ taxable income, giving closely held businesses a significant reason to consider converting.
IRS withdraws proposed net value requirement rule
The IRS withdrew rules it proposed in 2005 that would have required certain corporate formations and reorganizations to meet net value requirements before they would qualify for nonrecognition treatment.
Hidden insurance excise tax obligations arising from corporate chargebacks
When group policies are purchased from foreign insurance companies, there may be federal insurance excise tax issues.
Potential merger incentives resulting from proposed tax reform
The House Blueprint, if enacted, may provide incentives for certain taxpayers to merge in the future.
An obstructed view: Broad anti-abuse standard for consolidated returns
This column examines the meaning of the standard and discusses whether the economic substance doctrine still should be applied to a transaction that does not run afoul of the “with a view” standard.
Statistical sampling and resulting allocations under fixed-asset studies
This item discusses a methodology to sample expenditures by reviewing amounts capitalized for book purposes and to determine the extent to which they should be classified as tangible personal property or expensed for tax purposes.
A PATH to savings
This article examines the PATH act provisions and other developments favorable for taxpayers.
Boston Bruins can deduct full cost of meals for team’s away games
The Tax Court held that the owners of the Boston Bruins could deduct the full cost of their team’s pregame meals for away games as a de minimis fringe benefit.
Interim guidance on small business research tax credit allows amended returns to claim credit for 2016
Eligible small businesses can apply a portion of their R&D credit against their payroll tax liability under a new provision enacted in 2015.
IRS focuses on Sec. 199 for cable, satellite, and broadcast TV
Among the first wave of examination “campaigns” announced by the IRS’s LB&I is the application of the Sec. 199 domestic production activities deduction to “multi-channel video programming distributors.”
Leveraged spinoffs removed from IRS no-ruling list
The IRS says it will again issue rulings on corporate leveraged spinoff transactions.
Potential state tax consequences of the final and temporary Sec. 385 regs.
This item offers an overview of certain provisions in the regulations that could have state corporate income tax consequences.
IRS cannot recharacterize DISC commissions paid to Roth IRA
The IRS could not recharacterize, under the substance-over-form doctrine, commissions paid by a DISC to two Roth IRAs as dividends..
Minimizing gain in a dividend-equivalent redemption
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.
Corporate contraction and Sec. 382
This item focuses on stock redemptions, or transactions having the effect of a redemption, causing an ownership change.
Calendar-year C corporations can get 6-month filing extensions
The IRS is allowing calendar-year C corporations a six-month filing extension, instead of the five-month extension specified in the Code.
