C Corporation Income Taxation

TOPICS

April 1, 2018

Upstream, downstream: Upstream C reorganizations with a drop

The transaction accomplishes a distribution of assets to the parent, which may be effected in a tax-free manner only in limited circumstances.

April 1, 2018

Sec. 199 deduction for qualified film and the IRS compliance campaign approach

The IRS has created an LB&I compliance campaign that affects multichannel video programming distributors and television broadcasters.

March 13, 2018

Businesses affected by winter storms get extra time to file for extensions

The extension to March 20 applies to business taxpayers affected by the two recent winter storms, Quinn and Skylar, that primarily hit the Northeast and Mid-Atlantic United States.

March 1, 2018

IRS revisits General Utilities repeal

Provisions relating to the repeal of the General Utilities doctrine may again face scrutiny.

March 1, 2018

SEC permits reasonable estimates of tax liability to ease effect of new tax law

SEC allows companies to use reasonable estimates of their tax liability post-tax reform.

February 9, 2018

Bipartisan Budget Act contains several tax provisions

The Bipartisan Budget Act of 2018 has many tax provisions, including retroactive extensions of a number of tax credits.

February 1, 2018

Statistical sampling makes it easier to claim a research tax credit than ever before

Not just large but also medium-size and even smaller companies can more easily take a RTC now that the IRS allows multiple tax years under one statistical sample study.

February 1, 2018

Congress enacts tax reform

This column summarizes the federal tax law changes under reform enacted in December.

February 1, 2018

A new safe harbor for LB&I taxpayer R&D credits

A new directive allows taxpayers to use R&D costs reported on FASB ASC financial statements as the starting point for computing QREs.

February 1, 2018

IRS memorandum provides clarity on treatment of debt-issuance costs

The IRS concluded that a taxpayer could deduct the unamortized debt-issuance costs related to its existing debt upon its exchange for new debt.

January 2, 2018

SEC permits reasonable estimates in corporate tax reporting

Companies may initially have difficulty determining the effects of the new federal tax law on their income tax reporting.

January 1, 2018

When to use a tax-free reorganization

In some circumstances, a taxable stock sale may make more sense.

January 1, 2018

Safe harbor eliminates need for private letter ruling for some REIT and RIC distributions of stock and cash

The IRS established a safe harbor allowing distributions of stock to be treated as a distribution of property under Secs. 301 and 305(b) for publicly offered REITs or publicly owned RICs, as long as certain conditions are met.

January 1, 2018

Introducing U.S. equity crowdfunding: Potential risks and tax implications

New regulations issued by the SEC enable individual investors to invest in startup companies through equity crowdfunding.

January 1, 2018

Items and factors to consider in setting reasonable compensation

All companies should maintain supporting documentation for payments.

January 1, 2018

Income from receipt of carbon sequestration credits relating to timberlands is qualifying REIT income

The IRS ruled it would consider income recognized by a REIT in connection with the receipt of carbon sequestration credits to be income qualifying the taxpayer to be a REIT.

January 1, 2018

IRS withdraws portions of Subchapter C nonrecognition rules

Treasury and the IRS withdrew parts of proposed net value regulations that would require an exchange of net value for transactions intended to
qualify under Secs. 351 and 368 and a distribution of net value for transactions intended to qualify under Sec. 332.

December 20, 2017