Corporations - Gains & Losses

TOPICS / CORPORATIONS

December 1, 2019

Proposed rules would govern built-in gains and losses

The IRS issued proposed regulations that provide a safe harbor for corporations to calculate built-in gains and losses after an ownership change.

December 1, 2019

Liquidating an S corporation that is not subject to the BIG tax

Review how shareholders would be taxed on the gain from the sale of stock in an S corporation that is not affected by the built-in gains tax.

November 1, 2019

Stock redemption: Capital gain or ordinary income?

Sec. 302 affords a shareholder the advantage of sale or exchange (capital gain transaction) treatment on redeemed stock but only if the
redemption meets one of several tests.

September 10, 2019

Built-in gains and losses subject of new proposed regs.

The IRS issued proposed regulations that provide a safe harbor for corporations to calculate built-in gains and losses after an ownership change.

August 1, 2019

IRS provides clarity in second round of opportunity zone regulations

Several tax benefits can accrue to taxpayers that make investments in certain low-income communities through qualified opportunity funds. A second round of proposed regulations addresses many outstanding questions about this new vehicle for taxpayer-friendly investing in distressed communities.

August 1, 2019

IRS issues second set of proposed regulations on opportunity zones

This item discusses the clarifications and questions that were answered with the issuance of a second set of proposed regulations on May 1, 2019.

July 1, 2019

Restructuring with Sec. 987 QBUs? Watch for limitations under new Sec. 987 regs.

Before transferring Sec. 987 QBUs to related domestic or foreign parties, practitioners should consider the tax implications of the May final regulations.

July 1, 2019

IRS provides safe harbor for professional sports teams trading personnel contracts and draft picks

Rev. Proc. 2019-18 allows teams that fit within the safe harbor to treat the contracts as having a zero value for determining gain or loss.

July 1, 2019

Allocating previously taxed income in a Sec. 355 tax-free distribution

This discussion explores the allocation of E&P in a distribution to which Sec. 355 applies.

July 1, 2019

CFC worthless stock deductions after tax reform

This discussion focuses on the GILTI and BEAT implications for the benefit received by a U.S. corporation reporting a worthless stock deduction
under Sec. 165(g) for a CFC’s stock.

July 1, 2019

IRS issues more proposed regs. on qualified opportunity funds

The regulations define the term “substantially all,” the definition of which was reserved in the earlier proposed regulations issued in October 2018.

July 1, 2019

Traded player contracts and draft picks have zero value under safe harbor

The IRS will permit professional sports teams that trade player contracts to recognize zero gain if both parties to the exchange adopt the safe harbor and do not exchange cash.

May 1, 2019

Opportunities beckon in new qualified opportunity zones

With their prospects for deferral or even exclusion of gains from certain investments in them, the newly created qualified opportunity zones offer an intriguing tax planning option for investors and a potential boon for distressed communities.

April 17, 2019

More proposed regs. on qualified opportunity funds issued

The regulations define the term “substantially all,” the definition of which was reserved in the earlier proposed regulations issued in October 2018.

April 1, 2019

Sec. 1202: Consequences of capital contributions to closely held corporations

One of the requirements of Sec. 1202 is that the issuing corporation must be a qualified small business as of the date of issuance and immediately after the issuance.

March 6, 2019

Opportunities beckon in new qualified opportunity zones

February 1, 2019

First round of opportunity zone guidance offers flexibility for investors, but questions remain

Taxpayers should carefully review the proposed regulations for relevant limitations and be mindful of how future guidance may affect their investments.

February 1, 2019

Managing corporate state net operating losses

This article offers guidance on maximizing the use of corporate state NOLs, recording deferred
tax assets and valuation allowances for them, and incorporating their value in the pricing of M&A transactions.

February 1, 2019

IRS takes narrow view of aggregation under the at-risk rules

The IRS concluded that a taxpayer was not permitted to aggregate the S corporations with the partnership for the purpose of applying the at-risk rules of Sec. 465.

December 1, 2018

Capital gains deferral benefits of qualified opportunity zones

The TCJA created an incentive program that allows a taxpayer to elect to exclude from gross income
capital gain if it is properly reinvested in a qualified opportunity zone.