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TOPICS / CORPORATIONS

Minimizing a hobby loss issue by electing S status

To avoid the hobby
loss rules, with
their limitation on
deductible expenses,
an activity must be
engaged in for profit;
electing S status
can help a taxpayer
establish profit
motive.

Current developments in S corporations

This update on recent developments in taxation relating to S corporations includes cases and rulings on eligible terminated S corporations, S corporation income and losses, the one-class-of-stock requirement, and other issues.

The built-in gains tax

The built-in gains tax applies to C corporations that make an S corporation election, and it can
be assessed during the five-year period starting with the first tax year for which the S election is effective.

Consolidated groups get NOL guidance

The IRS issued proposed and temporary regulations explaining how consolidated groups should apply the changes to the net operating loss rules enacted by the CARES Act.

Hedging transactions: Timing of gain or loss

While the U.S. federal income tax rules generally provide comprehensive instruction on tax hedging transactions, ambiguity remains regarding the timing for transactions intended to hedge anticipated, but unfulfilled, transactions.