Corporations - Gains & Losses

TOPICS / CORPORATIONS

November 1, 2018

Qualified small business stock gets more attractive

The new lowered corporate tax rate will probably lead to more C corporations and a resulting increase in taxpayers’ interest in the Sec. 1202 100% exclusion on gain from the sale of QSB stock.

October 1, 2018

S corporation redemptions: Navigating Secs. 302 and 301

This discussion sheds light on these questions with an overview of the applications of Secs. 302 and 301 to S corporation redemptions.

August 1, 2018

Updates to Sec. 382 NUBIG and NUBIL safe harbors

With the increased use of stock acquisitions, buyers must correctly apply the Sec. 382 limitations, including the additional analysis to determine the impact of NUBIG and NUBIL.

June 1, 2018

Tax treatment of individual owners of bitcoin and other virtual currencies held for personal use or investment

Tax preparers will need to be proactive in helping their clients identify and report any potentially taxable transactions.

May 1, 2018

Code’s plain language prevails, despite anomalies

The owner of a hotel and restaurant complex was not entitled to capital gains treatment under Sec. 1234A for a deposit it retained after a would-be buyer terminated a contract to purchase the complex.

May 1, 2018

Sec. 336(e) elections for S corp. targets: Get a step-up without a letter ruling

Individuals, partnerships, or other noncorporate entities that could not benefit from a Sec. 338(h)(10) election may be able to qualify for a Sec. 336(e) election.

May 1, 2018

3-year holding period applies to S corporations

The IRS announced that S corporations are subject to the new extended three-year holding period applicable to carried interests.

March 1, 2018

Longer carried interest holding period includes S corporations

The IRS announced that the new three-year holding period for carried interests applies to S corporations as well as partnerships.

February 1, 2018

Dispute between shareholders did not strip taxpayers of beneficial rights of ownership

The Tax Court held that the taxpayers’ poor relations with other shareholders of an S corporation did not affect their ownership interest in the corporation.

January 1, 2018

IRS withdraws portions of Subchapter C nonrecognition rules

Treasury and the IRS withdrew parts of proposed net value regulations that would require an exchange of net value for transactions intended to
qualify under Secs. 351 and 368 and a distribution of net value for transactions intended to qualify under Sec. 332.

January 1, 2018