C Corporation Income Taxation

TOPICS

July 1, 2016

Sec. 108(i): Considerations for Electing Consolidated Groups

The regulations under Sec. 108(i) provide
special rules for consolidated groups.

June 7, 2016

Tax-Free REIT Spinoffs Are Curtailed

The IRS issued regulations restricting the ability of C corporations to use this method.

June 1, 2016

IRS Proposes Earnings-Stripping Rules, Issues Other Inversion Guidance

A package of proposed and temporary regulations are designed to reduce the tax benefits and incentives for corporate inversions.

June 1, 2016

Final Rules Define Loss Importation Property

The IRS issued final rules that prevent taxpayers from transferring losses to corporations.

June 1, 2016

Sec. 304 and Rev. Rul. 99-6: Fitting a Triangular Peg in a Round Hole

This item examines the potential application of Sec. 304 to transfers of interests in a partnership that owns corporate stock.

June 1, 2016

Foreign Currency Straddles and Transactions Present Complex Tax Issues

Foreign currency straddles may be used to manage foreign currency exposure, but they may carry hidden tax issues.

May 1, 2016

New Legislation Restricts Tax-Free REIT Spinoffs

The legislation curbs a popular tax planning strategy by severely restricting the application of tax-free spinoff treatment.

May 1, 2016

Tax Ethical and Penalty Issues in the UTP Context: A Review After Five Years of Experience

This column reviews the advent of Schedule UTP, considers the applicable ethical rules, and offers some best practice tips for practitioners.

May 1, 2016

Bonus Depreciation After the PATH Act

Congress made a notable change to the definition of qualifying property for bonus depreciation purposes.

May 1, 2016

Gain and Loss Recognition Under Sec. 356(c)

The Tax Court discussed the application of the “boot” rules under Sec. 356 in a tax-free reorganization.

May 1, 2016

Notice 2015-79: New Anti-Inversion Guidance

IRS inversion guidance introduces new restrictions on corporate inversions and post-inversion restructuring transactions.

May 1, 2016

Earnings Stripping: Effective Tax Strategy to Repatriate Earnings in a Global Economy

Earnings-stripping strategies can be an effective way to repatriate earnings at little or
no tax cost; however, taxpayers must be aware of the rules under Sec. 163(j).

May 1, 2016

Personal Goodwill and the Net Investment Income Tax

This article discusses when the sale
of goodwill related to a C corporation is the sale of a shareholder’s personal goodwill
and the reasons the gain from the sale of personal goodwill should not be subject to
the net investment income tax.

April 5, 2016

IRS’s Inversion Rules Include Earnings-Stripping Provisions

These new rules aim to curtail an inverted company’s ability to access foreign subsidiaries’ earnings without paying U.S. tax.

April 1, 2016

Recent Guidance Affecting Research Credit Carryforwards From Closed Years

The IRS recently promulgated final regulations that prohibit a taxpayer from increasing research credit carryforwards from closed years by electing the ASC method.

March 25, 2016

Loss Importation Rules Limit Built-In Losses

The Internal Revenue Service finalized rules that limit the ability of a taxpayer to transfer loss property to a corporation.

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.