C Corporation Income Taxation

TOPICS

September 1, 2018

Sec. 163(j) places renewed importance on tax shelter status

The exemption to the limitation on business interest under Sec. 163(j) does not apply to a tax shelter prohibited from using the cash-receipts-and-disbursements method of accounting under Sec. 448(a)(3).

September 1, 2018

Leasing property to a corporation

Shareholders can reap several benefits by leasing property to their corporation instead of transferring
ownership to the company.

September 1, 2018

Timing of the tax deduction for worthless intangibles

The challenge taxpayers frequently face is determining the date of sale, abandonment, or worthlessness.

September 1, 2018

LB&I campaigns update

The IRS’s LB&I division implemented a major restructuring intended to make better use of IRS
resources.

September 1, 2018

Restructuring foreign investment in U.S. real property

The TCJA has given a windfall benefit to foreign investors and developers in U.S. real estate due to the drop in the corporate tax rate from 35% to 21%.

August 22, 2018

IRS provides initial guidance on new Sec. 162(m)

The IRS issued guidance regarding amended Sec. 162(m), which limits the allowable deduction for remuneration paid by any publicly held corporation to a covered employee to $1 million.

August 7, 2018

Ninth Circuit withdraws Altera opinion

The order announcing the withdrawal says it is being done “to allow time for the reconstituted panel to confer on this appeal.”

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