C Corporation Income Taxation

TOPICS

August 1, 2017

IRS will rule on leveraged spinoffs again

The IRS says it will again issue rulings on corporate leveraged spinoff transactions.

July 12, 2017

IRS withdraws proposed net value requirement rule

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.

July 1, 2017

Hidden insurance excise tax obligations arising from corporate chargebacks

When group policies are purchased from foreign insurance companies, there may be federal insurance excise tax issues.

July 1, 2017

Potential merger incentives resulting from proposed tax reform

The House Blueprint, if enacted, may provide incentives for certain taxpayers to merge in the future.

July 1, 2017

An obstructed view: Broad anti-abuse standard for consolidated returns

This column examines the meaning of the standard and discusses whether the economic substance doctrine still should be applied to a transaction that does not run afoul of the “with a view” standard.

July 1, 2017

Statistical sampling and resulting allocations under fixed-asset studies

This item discusses a methodology to sample expenditures by reviewing amounts capitalized for
book purposes and to determine the extent to which they should be classified as tangible personal property or expensed for tax purposes.

June 29, 2017

A PATH to savings

This article examines the PATH act provisions and other developments favorable for taxpayers.

June 27, 2017

Boston Bruins can deduct full cost of meals for team’s away games

The Tax Court held that the owners of the Boston Bruins could deduct the full cost of their team’s pregame meals for away games as a de minimis fringe benefit.

June 1, 2017

IRS focuses on Sec. 199 for cable, satellite, and broadcast TV

Among the first wave of examination “campaigns” announced by the IRS’s LB&I is the application of the Sec. 199 domestic production activities deduction to “multi-channel video programming distributors.”

June 1, 2017

Interim guidance on small business research tax credit allows amended returns to claim credit for 2016

Eligible small businesses can apply a portion of their R&D credit against their payroll tax liability under a new provision enacted in 2015.

May 10, 2017

Leveraged spinoffs removed from IRS no-ruling list

The IRS says it will again issue rulings on corporate leveraged spinoff transactions.

May 1, 2017

Potential state tax consequences of the final and temporary Sec. 385 regs.

This item offers an overview of certain provisions in the regulations that could have state corporate income
tax consequences.

May 1, 2017

IRS cannot recharacterize DISC commissions paid to Roth IRA

The IRS could not recharacterize, under the
substance-over-form doctrine, commissions paid by a DISC to two Roth IRAs as dividends..

May 1, 2017

Calendar-year C corporations can get 6-month filing extensions

The IRS is allowing calendar-year C corporations
a six-month filing extension, instead of the five-month extension specified in the Code.

May 1, 2017

Minimizing gain in a dividend-equivalent redemption

This item presents an opportunity to minimize the tax impact of a distribution by a closely held corporation that is not made out of the corporation’s E&P.

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.

May 1, 2017

Identifying constructive dividends to shareholders

This column discusses examples of potential constructive dividends.

April 11, 2017

Micro-captive insurance disclosure statement deadline approaching

Taxpayers who have engaged in “micro-captive transactions,” which the Internal Revenue Service has designated as transactions of interest, have until May 1 to file the required disclosure statement.

April 1, 2017

Proposed ‘hot dog stand’ regulations for spinoffs

The proposed regulations are intended to further limit a corporation’s ability to separate business assets from nonbusiness assets in a tax-free manner.

April 1, 2017

IRS issues reasonable internal-use software regulations for the research tax credit

The final regulations could provide opportunities for companies and industries that previously did not include expenditures for software developed primarily for their own internal use.