C Corporation Income Taxation

TOPICS

February 1, 2017

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.

February 1, 2017

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.

February 1, 2017

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.

February 1, 2017

Uncertainty Surrounding Back-to-Back F Reorganizations

The tension between the two principles of the new regulations can cause taxpayers uncertainty.

February 1, 2017

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.

February 1, 2017

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.

February 1, 2017

Fifth Circuit Finds Fault With Tax Court’s Definition of “Bank”

Fifth Circuit vacated Tax Court’s decision that MoneyGram International Inc. was not a bank because the Tax Court applied incorrect definitions
of “deposits” and “loans.”

January 19, 2017

Sec. 385 Regulations Impose Intergroup Debt Requirements

The final and temporary regulations substantially revised the proposed regulations, reducing their scope.

January 12, 2017

Planning to Comply With the New U.S. Debt-Equity Requirements

Companies should develop plans to ensure both tax and financial reporting compliance.

January 1, 2017

Final Earnings-Stripping Regulations Exempt Many Taxpayers

Final regulations expand on and modify the proposed rules that curb the practice of “earnings stripping.”

January 1, 2017

IRS Clarifies Definition of “Construction of Real Property” for Purposes of Sec. 199

The IRS determined a taxpayer’s substantial renovation, construction, and erection of certain
property qualified as the construction of real property under Sec. 199.

January 1, 2017

IRS Eliminates No-Rule Policy for Business Purpose and Device Rule Issues

The application of the business purpose and device rules often involves both legal and factual questions.

January 1, 2017

Ascertaining the Tax Impact on the Shareholder of a Corporate Assumption of Liabilities in a Sec. 351 Transfer

The transfer of debt to a corporation will create a taxable event in some situations.

January 1, 2017

Final Regulations Clarify Definition of Real Property for REITs

The IRS issued final regulations clarifying the definition of real property for purposes of the REIT provisions.

January 1, 2017

How to Document a Tax-Free D Reorganization With a Split-Off

A taxpayer that treats a split-off transaction
as a tax-free D reorganization must be able to
prove to the IRS that the transaction meets all requirements.

December 16, 2016