The IRS says it will again issue rulings on corporate leveraged spinoff transactions.
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TOPICS
C Corporation Income Taxation
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.
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..
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.
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.
Corporate contraction and Sec. 382
This item focuses on stock redemptions, or transactions having the effect of a redemption, causing an ownership change.
Identifying constructive dividends to shareholders
This column discusses examples of potential constructive dividends.
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.
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.
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.
How small businesses can apply the research credit to payroll taxes
Eligible small businesses can apply a portion of their research and development credit against their payroll tax liability, starting with 2016 tax years, under a new provision enacted in 2015.
Bonus Depreciation: The PATH Act and Beyond
In addition to extending bonus depreciation and phasing out the bonus rate, the PATH Act made several changes to the types of eligible property
under Sec. 168(k)(2).
IRS confirms 6-month extensions for calendar-year C corps.
The IRS posted to its website confirmation that it is allowing calendar-year C corporations a six-month filing extension, despite statutory language that specifies a five-month extension for calendar-year C corporations.
Sec. 385 Regs.: Five Key Themes Every Company Needs to Know
This item outlines some of the more common themes that came out of the final and temporary regulations.
Related-Party Like-Kind Exchange Had Tax-Avoidance Purpose, Court Holds
A taxpayer was not entitled to defer gain on a disposition of property to a related party that met the Sec. 1031(a) requirements for a like-kind exchange.
Final R&D Internal-Use Software Regulations Provide More Certainty
Regulations settle much of the uncertainty for determining when software is developed for internal use.
IRS Does Not Acquiesce to Treatment of Discounts in Giant Eagle
Taxpayers should expect to see continued controversy
regarding when a liability is fixed for customer discounts.
Uncertainty Surrounding Back-to-Back F Reorganizations
The tension between the two principles of the new regulations can cause taxpayers uncertainty.
Sec. 1234A and Termination Fees
This item provides a brief history of existing tax law in this area and IRS guidance and a summary of the recent developments.
When Entity Simplification Is Not So Simple
Carrying over E&P from one entity to another and administrative burdens can lead to
headaches down the road.
TAX PRACTICE MANAGEMENT
2025 tax software survey
AICPA members in tax practice assess how their return preparation software performed during tax season and offer insights into their procedures.
