C Corporation Income Taxation

TOPICS

December 1, 2016

Why Personal Service Corporations Should Care About the Amount Paid to Shareholders

Personal service corporations risk having compensation reclassified as dividends, which are subject to double taxation.

December 1, 2016

Some Internal-Use Software Qualifies for Research and Development Credit

Taxpayers that develop software for their own internal use will be able to claim a credit for research and development expenditures in some cases.

December 1, 2016

Permanent Tax Savings Available Through the Use of an IC-DISC

IC-DISC provides a permanent tax benefit to
entities that export products that are manufactured, grown, or extracted in the United States.

November 1, 2016

Rev. Rul. 2016-15 and the Uniform Application of Sec. 108 to QRPBI

Real property developed and held by a taxpayer for lease in its leasing business is “real property used in a trade or business.”

November 1, 2016

Should the United States Enact a Patent Box?

Many countries have implemented preferential
tax systems to bolster incentives to keep research and innovation activities onshore.

November 1, 2016

Tax Court Finds Compensation Reasonable, Rejects IRS Attempt to Modify Independent-Investor Test

In this case, compensation paid by a closely held corporation was reasonable and therefore deductible.

November 1, 2016

IRS Updates Safe Harbor on Contributions to Capital for Transfers to Public Utilities

These transfers are considered a nontaxable contribution of capital by a nonshareholder to the utility.

November 1, 2016

Acquired Taxpayer Is Not Eligible for Success-Based Fee Safe Harbor of Rev. Proc. 2011-29

An S corporation was not eligible to elect the safe harbor since it was the target of the acquisition, and it must capitalize the success-based fees that it claimed as an expense.

November 1, 2016

Dental Practice’s Management Fees Were Not Ordinary and Necessary Business Expenses

The fees were unnecessary because the taxpayer did not provide proof to show that any services were actually performed in exchange for the fees.

November 1, 2016

Clarification of the Fair Market Value Calculation for the Discharged QRPBI Exclusion

Recently issued advice clarifies some of the rules regarding the limitations on the amount of the exclusion.

November 1, 2016

Transaction Pursuant to Qualified Stock Purchase Treated as Distribution in Liquidation

A Sec. 338 election can provide benefits to buyer and seller, but the transaction must be structured so that it satisfies the conditions to be a qualified
stock purchase.

October 14, 2016

Earnings-Stripping Rules Make Many Changes From Proposed Regs.

The new rules are part of the Treasury Department’s larger effort to curb corporate inversions.

October 3, 2016

Final Rules Allow Credit for Development of Internal-Use Software in Some Cases

Software a taxpayer develops for its own general and administrative internal use can qualify for the research and development credit under regulations finalized by the IRS.

October 1, 2016

Third-Party Borrowing and the Sec. 385 Prop. Regs.: End-Around or Hail Mary?

The proposed regulations target three types of transactions formerly considered well-established and routine mechanisms for creating internal leverage within a controlled group’s entity structure.

October 1, 2016

R&D Tax Credit Changes Benefit Small Businesses

The PATH Act of 2015 included important changes to the R&D credit.

September 1, 2016

Debt Restructurings and Contingencies

This item addresses the tax consequences when a nonpublic, financially healthy company renegotiates a debt that was incurred to purchase the company’s assets, and the resulting new debt is contingent on the occurrence of future events.

September 1, 2016

Understanding the Problems of PHC Status

Tax problems and administrative difficulties can arise if a corporation is classified as a personal holding company.

September 1, 2016

Documenting Deductible Transaction Costs for Acquisitive Transactions

This item discusses the ability of a target in a Sec. 338(h)(10) transaction to use the safe-harbor election provided by Rev. Proc.
2011-29.

August 1, 2016

Complexities of Stock Deals in M&A Transactions

Proper planning needs to take place to avoid the potential negative tax consequences and complexities of a taxable stock purchase.

August 1, 2016

Corporations Restricted From Tax-Free REIT Spinoffs

Temporary and proposed regulations implement the amendments to the real estate investment trust spinoff rules.

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C Corporation Income Taxation

Why Personal Service Corporations Should Care About the Amount Paid to Shareholders

Some Internal-Use Software Qualifies for Research and Development Credit

Permanent Tax Savings Available Through the Use of an IC-DISC

Rev. Rul. 2016-15 and the Uniform Application of Sec. 108 to QRPBI

Should the United States Enact a Patent Box?

Tax Court Finds Compensation Reasonable, Rejects IRS Attempt to Modify Independent-Investor Test

IRS Updates Safe Harbor on Contributions to Capital for Transfers to Public Utilities

Acquired Taxpayer Is Not Eligible for Success-Based Fee Safe Harbor of Rev. Proc. 2011-29

Dental Practice’s Management Fees Were Not Ordinary and Necessary Business Expenses

Clarification of the Fair Market Value Calculation for the Discharged QRPBI Exclusion

Transaction Pursuant to Qualified Stock Purchase Treated as Distribution in Liquidation

Earnings-Stripping Rules Make Many Changes From Proposed Regs.

Final Rules Allow Credit for Development of Internal-Use Software in Some Cases

Third-Party Borrowing and the Sec. 385 Prop. Regs.: End-Around or Hail Mary?

R&D Tax Credit Changes Benefit Small Businesses

Debt Restructurings and Contingencies

Understanding the Problems of PHC Status

Documenting Deductible Transaction Costs for Acquisitive Transactions

Complexities of Stock Deals in M&A Transactions

Corporations Restricted From Tax-Free REIT Spinoffs

TAX PRACTICE MANAGEMENT

2025 tax software survey

Tax Clinic

IRS generally eliminates 5% safe harbor for determining beginning of construction for wind and solar projects

IRS proposes using NAICS to determine lines of business for certain fringe benefit exclusions

IRS rules that community trust and affiliated nonprofit corporation can file a single Form 990

Prop. regs. issued on new qualified tips deduction

IRS rules for first time that REIT’s income from markup on electricity from EV charging stations is rents from real property

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