This item highlights three often overlooked or misunderstood factors potentially disrupting international transactions.
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TOPICS / CORPORATIONS
Gains & Losses
Prop. regs. would eliminate Sec. 338 safe harbor, modify calculations
This discussion provides an overview of the current Sec. 382 regime, and then discusses the significant
changes in the proposed regulations and their implications.
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.
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.
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.
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.
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.
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.
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.
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.
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.
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.
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.
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.
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.
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.
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.
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.
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.
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.
PRACTICE MANAGEMENT
2026 tax software survey
CPAs rate their return preparation software’s performance during this year’s tax season.
