C Corporation Income Taxation

TOPICS

March 21, 2016

Regulations Finalize Coordination Rules for Outbound Reorganizations

The IRS issued regulations that eliminate an exception to the coordination rule between asset transfers and indirect stock transfers for certain outbound asset reorganizations and modify an exception to the coordination rule.

March 1, 2016

“Cadillac” Health Plan Excise Tax Delayed Until 2020

The so-called Cadillac plan excise tax is now scheduled to take effect in 2020.

February 9, 2016

President’s Budget Proposes Many Tax Changes

In addition to a proposed spending blueprint for the government, President Barack Obama’s proposed FY 2017 federal budget contains a wide variety of tax law changes that would affect individuals and businesses.

February 1, 2016

Practical Strategies for Using Sampling for the Research Tax Credit

This item discusses efficient strategies for a tax department to consider when planning a statistical sample to estimate qualified research
expenditures.

February 1, 2016

Final F Reorganization Regs. Might Make Treatment Available for Reverse Mergers

A company that uses a reverse merger to go public generally would like to structure the merger as a tax-free reorganization.

February 1, 2016

Sec. 163(I)’s “Substantial Certainty” Test and Related-Party Convertible Debt

This item summarizes the current law and discusses the facts and conclusion in Letter Ruling 201517003.

February 1, 2016

New Rules Aimed at Further Curtailing Inversions

The IRS announced new rules rules designed to curtail the ability of an inverted company to access foreign subsidiaries’ earnings without paying U.S. tax.

January 1, 2016

Recognizing and Measuring Tax Benefits From Uncertain Tax Positions

Once all uncertain tax positions have been identified, FASB Accounting Standards creates a two-step process to recognize and measure the tax benefits arising from those positions.

December 16, 2015

Tax Extender Legislation Introduced in Congress

The Consolidated Appropriations Act introduced in Congress on Wednesday would extend a large number of expired tax provisions.

December 1, 2015

IRS Finalizes Potential F Reorganization Rules

Corporations that meet six requirements will be able to effectuate F reorganizations tax-free in some cases.

November 20, 2015

New Corporate Anti-Inversion Rules Issued

The IRS announced additional rules designed to curtail the ability of an inverted company to access foreign subsidiaries’ earnings without paying U.S. tax.

November 1, 2015

Acquisition of Partnership Interest Constitutes an Expansion of Distributing Corporation’s Business

The IRS ruled that a distributing corporation’s
acquisition of an interest in a partnership was not an acquisition of a new or different business.

November 1, 2015

Proposed Regulations Would Provide Guidance for Allocation and Absorption of Losses on a Consolidated Return

Proposed regulations address an issue when there is a consolidated net operating loss.

November 1, 2015

Applicability of Sec. 1031 in Exchange of Agreements

Selling off and replacing assets could result in a possible taxable gain. A common business practice for avoiding such a gain is to engage in a Sec. 1031 exchange.

October 29, 2015

Should Some Frequent Flier Miles Be Exempt From Excise Tax?

The IRS on Thursday asked for feedback on whether frequent flier miles that are redeemed for anything other than taxable air transportation should be exempt from the Sec. 4261 excise tax.

October 15, 2015

Expired Tax Provisions: No Relief in Sight?

It’s a good time to review which provisions might get a last minute reprieve and see what legislation is pending in Congress.

October 8, 2015

Tax Planning Businesses Can Do Before Year End

Here are some suggestions to help business clients reduce 2015 taxes by accelerating deductions into this year and delaying income until next year.

October 1, 2015

IRS Expands Range of D Reorganizations, Highlights Importance of the Form of a Taxpayer’s Transaction

IRS rules expand the range of transactions that qualify as type D acquisitive asset reorganizations and signaled a greater willingness to accept a taxpayer’s chosen form of reorganization transaction.

October 1, 2015

Capitalization Not Required for Payment to Terminate Management Agreement Prior to IPO

In a Letter Ruling, the IRS concluded that a payment made to terminate a management services agreement did not create an intangible asset or facilitate a transaction.

September 18, 2015

Final Rules Govern F Reorganizations

The final rules apply a concept called a potential F reorganization, allowing the many steps of a corporate reorganization to be examined together to see if the transaction qualifies to be an F reorganization.