C Corporation Income Taxation

TOPICS

December 1, 2017

Reducing taxes with qualified patronage dividends

Cooperative corporations can shield net income from taxation by returning it to the patrons in the form of qualified patronage dividends.

December 1, 2017

Flexible ownership incentives for key employees

To reward and retain key employees, companies often
look for ways to extend ownership or the feeling of ownership.

December 1, 2017

Leased farmland and the active business requirement for a tax-free reorganization

Meeting the active trade or business requirement is critical to ensuring a corporation leasing farmland qualifies for a tax-free divisive reorganization.

December 1, 2017

Substantive consolidation: A tale of two cases

Because there is no clear statutory guidance for how a bankruptcy judge determines if a trustee’s request to apply substantive consolidation should be granted, each case is different.

December 1, 2017

IRS announces it will rule on tax-free stock distributions

The IRS is introducing an 18-month pilot program under which it will once again issue letter rulings concerning the general income tax effects of stock distributions under Sec. 355.

November 7, 2017

Foreign income provisions in the Tax Cuts and Jobs Act

The House’s tax reform bill would make many changes to the taxation of US companies’ foreign subsidiaries.

November 6, 2017

House bill features many business tax changes

The House tax reform bill contains a large number of proposed changes that would affect businesses.

November 1, 2017

Phantom stock: Termination of right to buy or sell, treatment of asset and basis

The Tax Court considered whether redemption of phantom stock was a sale of a capital asset and
what the tax basis in the redeemed phantom stock was.

November 1, 2017

Letter ruling provides guidance on distributions in a reorganization

The IRS ruled on how the distribution of stock is treated in a tax-free reorganization and whether there is any potential recognition of gain.

October 1, 2017

Recommendations for charitable contributions made by businesses

This column discusses the treatment and classification of contributions made by businesses.

October 1, 2017

Net value requirement for tax-free reorganization treatment withdrawn

The IRS withdrew rules it proposed in 2005 that would have required certain corporate formations and reorganizations to meet net value requirements before they would qualify for nonrecognition treatment.

October 1, 2017

Fuel blending and the Sec. 199 deduction

This column discusses whether fuel blending may be
treated as a domestic production activity for purposes of the DPAD deduction.

October 1, 2017

Tax Court: Sports team allowed 100% meal deduction when traveling for road games

The U.S. Tax Court held that a professional hockey team could deduct the cost of meals provided to players and other employees at the team’s hotel
while traveling for games.

October 1, 2017

Key aspects of maintaining a global workforce

Employees should have overarching guidance for their global assignment that includes international assignment agreements.

October 1, 2017

Gross receipts definition in R&D credit may limit its benefit to startups

Since the R&D tax credit is a nonrefundable credit, startup companies are frequently limited in their ability to claim it in the current tax year because
they have net operating losses.

October 1, 2017

Boston Bruins can deduct 100% of cost of certain pregame meals

The U.S. Tax Court held that pregame meals provided to players and personnel before away games qualify as a de minimis fringe benefit.

September 22, 2017

IRS to rule on tax-free stock distributions

The IRS is introducing an 18-month pilot program under which it will once again issue letter rulings concerning the general income tax effects of stock distributions under Sec. 355.

September 1, 2017

Deducting startup and expansion costs

Certain business expenses incurred to start or expand a business can be currently deducted.

September 1, 2017

Tax Court allows full meal deduction for NHL team’s away games

Pregame meals provided to Boston Bruins players and personnel before away games qualify as a de minimis fringe benefit.

August 1, 2017

Will tax reform make C corps. more attractive for closely held businesses?

Tax reform is expected to reduce the tax rates imposed on C corporations’ taxable income, giving closely held businesses a significant reason to consider converting.