C Corporation Income Taxation

TOPICS

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.

July 21, 2016

Charitable Donations of Food Inventory

A recent change in the law makes it easier for taxpayers to claim charitable deductions for food products donated to charity.

July 15, 2016

IRS Provides Safe Harbors for Acquisition of Control in Certain Corporate Transactions

The IRS issued guidance that provides safe harbors for corporations, under which the IRS will not assert that a distributing corporation lacks control of another corporation within the meaning of Sec. 355(a)(1)(A).

July 1, 2016

Double and Triple Drops With Liquidations Clarified in Pair of Revenue Rulings

This item discusses these rulings along with the technical aspects surrounding their issuance and addresses whether the IRS reached the right results.

July 1, 2016

Practical Documentation of QRAs for the R&D Tax Credit

In the absence of records specifically created to document the research tax credit, taxpayers
often have to rely on estimates and an assortment of documents, interviews, and other evidence to substantiate expenditures that qualify for the research tax credits.

July 1, 2016