Collaboration agreements, especially in the life sciences, sometimes unexpectedly transcend state boundaries, with consequences for companies’ apportionment and sales factor revenue sourcing.
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TOPICS / CORPORATIONS
Gains & Losses
Practical considerations for NUBIL positions under Sec. 382
Proactive management of net unrealized built-in losses in ownership changes is increasingly important in today’s volatile markets.
Interaction of S shareholders’ loss limitations
Shareholder basis and other applicable loss limitations must be applied in a specified order, with differing rules.
PTE deduction: Timing issues for accrual-method taxpayers
taxpayers and practitioners face uncertainty regarding the timing of the deduction provided for in Notice 2020-75.
Identifying corporations subject to the at-risk rules
The at-risk rules limit the losses allowed to closely held C corporations on certain investments, testing each separate activity to determine if the corporation is at risk for that activity.
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.
Superseding returns and statutes of limitation
CARES Act provisions on net operating losses place new spotlight on the effect of filing superseding returns.
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.
Handling tax issues related to noncompete agreements
Covenants not to compete can protect a company’s interest as long as they are drafted in an appropriate manner, but their 15-year amortization period can cause issues.
Avoiding gain at the S shareholder level when a loan is repaid
When the basis in an S shareholder’s loan to the S corporation has been reduced by passthrough losses, repayment of the loan may be a taxable
event.
IRS issues final regulations on consolidated group NOLs
The IRS finalized regulations governing the treatment of net operating losses by consolidated groups after recent legislation changed the rules.
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 group NOL rules are finalized
The IRS finalized regulations governing the treatment of net operating losses by consolidated groups after recent legislation changed the rules.
Regulation package defines NOL rules for consolidated groups
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.
Interplay between NOL carrybacks and the AMT
This discussion focuses on how the AMT rules impact the NOL rules under the CARES Act.
Overpayment due to minimum tax credit is attributable to NOL carryback
Refund claim for overpayment caused by credit is
attributable to net operating loss for purposes of the Sec. 6511(d)(2) limitation period.
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.
Liquidity and cash management strategies during a pandemic
The CARES Act creates several opportunities for businesses to shore up cash flow.
Top 10 business income tax planning ideas for the pandemic
Right now, some basic tax planning ideas can make a significant difference in reducing income tax, thereby increasing cash flow and even creating tax refund opportunities.
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.
PRACTICE MANAGEMENT
2026 tax software survey
CPAs rate their return preparation software’s performance during this year’s tax season.
