Corporations - Gains & Losses

TOPICS / CORPORATIONS

May 1, 2017

Corporate contraction and Sec. 382

This item focuses on stock redemptions, or transactions having the effect of a redemption, causing an ownership change.

February 1, 2017

Related-Party Like-Kind Exchange Had Tax-Avoidance Purpose, Court Holds

A taxpayer was not entitled to defer gain on a disposition of property to a related party that met the Sec. 1031(a) requirements for a like-kind exchange.

February 1, 2017

Sec. 1234A and Termination Fees

This item provides a brief history of existing tax law in this area and IRS guidance and a summary of the recent developments.

January 1, 2017

Ascertaining the Tax Impact on the Shareholder of a Corporate Assumption of Liabilities in a Sec. 351 Transfer

The transfer of debt to a corporation will create a taxable event in some situations.

August 1, 2016

Corporations Restricted From Tax-Free REIT Spinoffs

Temporary and proposed regulations implement the amendments to the real estate investment trust spinoff rules.

June 1, 2016

Final Rules Define Loss Importation Property

The IRS issued final rules that prevent taxpayers from transferring losses to corporations.

June 1, 2016

Sec. 304 and Rev. Rul. 99-6: Fitting a Triangular Peg in a Round Hole

This item examines the potential application of Sec. 304 to transfers of interests in a partnership that owns corporate stock.

June 1, 2016

Foreign Currency Straddles and Transactions Present Complex Tax Issues

Foreign currency straddles may be used to manage foreign currency exposure, but they may carry hidden tax issues.

May 1, 2016

Gain and Loss Recognition Under Sec. 356(c)

The Tax Court discussed the application of the “boot” rules under Sec. 356 in a tax-free reorganization.

March 25, 2016

Loss Importation Rules Limit Built-In Losses

The Internal Revenue Service finalized rules that limit the ability of a taxpayer to transfer loss property to a corporation.

November 1, 2015

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.

November 1, 2015

Applicability of Sec. 1031 in Exchange of Agreements

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.

September 4, 2015

Rules Target Abuse of “Legging Out” of Foreign Currency Hedges

Final regulations issued on Friday clarify the tax treatment of certain terminations of qualified hedging transactions under Sec. 988.

September 1, 2015

Statute of Limitation for Tax Carryovers

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.

September 1, 2015

IRS Prohibits Corporations From Circumventing Gain on Appreciated Property Using Partnerships

The IRS issued more regulations that take aim at transactions that attempt to avoid the repeal of the General Utilities doctrine.

July 30, 2015

Attacking Transactions to Evade General Utilities Repeal

Temporary regulations prevent corporations from avoiding tax through the use of partnerships.

March 1, 2015

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.

February 1, 2015