C Corporation Income Taxation

TOPICS

August 2, 2018

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).

August 1, 2018

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.

August 1, 2018

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.

August 1, 2018

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.

August 1, 2018

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.

July 25, 2018

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.

July 1, 2018

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).

July 1, 2018

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.

July 1, 2018

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.

June 1, 2018

How the 2017 tax overhaul changed Sec. 162(m)

This article discusses how the TCJA altered corporations’ responsibilities and the potential compensation implications.

June 1, 2018

IRS issues first guidance on new business interest limitation

The IRS issues guidance on business interest limitation under the new tax act.

June 1, 2018

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.

June 1, 2018

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.

June 1, 2018

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.

May 1, 2018

Deducting deferred bonuses

Numerous rules and restrictions govern the timing
of deductibility of bonuses accrued in one year and paid in another.

May 1, 2018

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.

May 1, 2018

Application of Sec. 199A deduction to health care

While businesses involving the performance of services in the health care field were generally understood as not qualifying for the Sec. 199A deduction, further analysis could provide a favorable result.

May 1, 2018

Casualty losses and expenditures under Sec. 162 or 165

Two Code provisions, Sec. 162 and Sec. 165, offer a potential deduction for a taxpayer who has property that has been damaged by a casualty.

April 1, 2018

Converting from S corp. to C corp.: Select issues for consideration

As a result of tax reform, which provides for a significant decrease in the corporate tax rate and a more modest decrease in passthrough tax rates, business owners may consider revoking S corporation elections.

April 1, 2018