This item focuses on stock redemptions, or transactions having the effect of a redemption, causing an ownership change.
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TOPICS / CORPORATIONS
Gains & Losses
Losses disallowed where S corp. not indebted to shareholder
The Tax Court held that an S corporation shareholder could not claim losses from several wholly owned S corporations due to insufficient basis.
Tax Court upholds non-safe-harbor reverse like-kind exchange
The Tax Court’s decision in Estate of Bartell alleviates uncertainty about structuring
a reverse like-kind exchange intended to qualify for nonrecognition treatment.
Ordinary loss deductions under Sec. 165(g)(3) in the S corp. context
This item discusses whether S corporations should be entitled to an ordinary loss under Sec. 165(g)(3) as a matter of law.
Disposing of passive activities
Disposing of property related to a passive activity does not resolve all matters related to the property.
Related-Party Like-Kind Exchange Had Tax-Avoidance Purpose, Court Holds
A taxpayer was not entitled to defer gain on a disposition of property to a related party that met the Sec. 1031(a) requirements for a like-kind exchange.
Sec. 1234A and Termination Fees
This item provides a brief history of existing tax law in this area and IRS guidance and a summary of the recent developments.
Ascertaining the Tax Impact on the Shareholder of a Corporate Assumption of Liabilities in a Sec. 351 Transfer
The transfer of debt to a corporation will create a taxable event in some situations.
Royalties on Pharmaceutical Technology Taxable as Ordinary Income, Tax Court Holds
Tax Court held that royalties received by an S corporation under a license agreement are taxable as ordinary income to the S corporation’s individual shareholder.
Corporations Restricted From Tax-Free REIT Spinoffs
Temporary and proposed regulations implement the amendments to the real estate investment trust spinoff rules.
Final Rules Define Loss Importation Property
The IRS issued final rules that prevent taxpayers from transferring losses to corporations.
Sec. 304 and Rev. Rul. 99-6: Fitting a Triangular Peg in a Round Hole
This item examines the potential application of Sec. 304 to transfers of interests in a partnership that owns corporate stock.
Foreign Currency Straddles and Transactions Present Complex Tax Issues
Foreign currency straddles may be used to manage foreign currency exposure, but they may carry hidden tax issues.
Gain and Loss Recognition Under Sec. 356(c)
The Tax Court discussed the application of the “boot” rules under Sec. 356 in a tax-free reorganization.
Changes to the BIG Recognition Period of Sec. 1374(d)(7)
The potential effect of the built-in-gain tax is often a significant consideration during pending acquisitions involving an S corporation.
Loss Importation Rules Limit Built-In Losses
The Internal Revenue Service finalized rules that limit the ability of a taxpayer to transfer loss property to a corporation.
Calculating Basis in Debt
Direct shareholder loans to an S corporation can be very important tools for tax planning.
Proposed Regulations Would Provide Guidance for Allocation and Absorption of Losses on a Consolidated Return
Proposed regulations address an issue when there is a consolidated net operating loss.
Applicability of Sec. 1031 in Exchange of Agreements
Selling off and replacing assets could result in a possible taxable gain. A common business practice for avoiding such a gain is to engage in a Sec. 1031 exchange.
Should S Corporations Get Ordinary Loss Treatment for Losses on Subsidiary Stock?
The question of whether an S corporation should be treated the same as a C corporation when its subsidiary corporation is insolvent has not been definitively answered.
PRACTICE MANAGEMENT
2026 tax software survey
CPAs rate their return preparation software’s performance during this year’s tax season.
