Foreign currency straddles may be used to manage foreign currency exposure, but they may carry hidden tax issues.
Gains & Losses
The IRS issued final rules that prevent taxpayers from transferring losses to corporations.
This item examines the potential application of Sec. 304 to transfers of interests in a partnership that owns corporate stock.
The Tax Court discussed the application of the “boot” rules under Sec. 356 in a tax-free reorganization.
The Internal Revenue Service finalized rules that limit the ability of a taxpayer to transfer loss property to a corporation.
Selling off and replacing assets could result in a possible taxable gain. A common business practice for avoiding such a gain is to engage in a Sec. 1031 exchange.
Proposed Regulations Would Provide Guidance for Allocation and Absorption of Losses on a Consolidated Return
Proposed regulations address an issue when there is a consolidated net operating loss.
Final regulations issued on Friday clarify the tax treatment of certain terminations of qualified hedging transactions under Sec. 988.
The IRS issued more regulations that take aim at transactions that attempt to avoid the repeal of the General Utilities doctrine.
It is not unusual for a taxpayer to make an error on a return that results in a misstatement of a net operating loss or a credit that is then carried forward. These mistakes might not be noticed until after the statute of limitation is closed.
Temporary regulations prevent corporations from avoiding tax through the use of partnerships.
Proposed Regulations Would Require Gain or Loss Recognition on Certain Installment Obligation Transfers
The IRS issued proposed regulations that would require transferors that transfer installment obligations for equity interests in corporations or partnerships in nonrecognition transactions in satisfaction of those obligations to recognize gain or loss.
Pharmaceutical companies confront several tax differences when determining whether a transaction is a license or sale.
IRS clarified that the amendment to Sec. 56(d) made by the WHBAA did not create new ordering rules for absorbing ATNOLs.
The IRS issued proposed regulations relating to the nonrecognition of gain or loss on certain dispositions of an installment obligation.
The IRS finalized proposed regulations to update the rules that apply to U.S. taxpayers that fail to file gain recognition agreements when they transfer certain property to foreign corporations in nonrecognition transactions.
For many years, taxpayers have been able to defer recognition of gain on the disposition of assets by engaging in Sec. 1031 like-kind exchanges. Consequently, many questions and issues surrounding these transactions have been addressed, but many cases and rulings continue to arise each year. This article analyzes these cases and rulings and identifies questions that still need to be answered.
Change the character of a loss from ordinary to capital, and a taxpayer runs the risk of deferring or even failing to realize a tax benefit. While the general rules regarding characterization of gains or losses are well-known, more obscure statutory provisions can change an otherwise ordinary gain or loss into a capital gain or loss.
The Court of Federal Claims denied approximately $1.6 billion in cost basis related to decommissioning liabilities assumed in connection with the purchase of three nuclear power plants.
The IRS issued final regulations under Sec. 362(e)(2) that provide guidance on the determination of the bases of assets (including stock) transferred in certain nonrecognition transactions to which Sec. 362(e)(2) limitations on built-in losses apply.