Clients who wish to have income from services be treated as income of their corporations should have revise independent contractor agreements so that payments are made to their corporations.
Disposing of property related to a passive activity does not resolve all matters related to the property.
This item discusses whether S corporations should be entitled to an ordinary loss under Sec. 165(g)(3) as a matter of law.
Income earned by financial adviser was his, not the income of his wholly owned S corporation, and was therefore subject to self-employment tax.
The AICPA Task Force is developing a position paper with possible approaches that state CPA societies may want to consider in working with state legislatures and tax authorities in developing compliance policies.
This article reviews and analyzes recent law changes as well as rulings and decisions involving partnerships.
This column focuses on what happens when a partnership’s business activities cease.
The IRS released a package of proposed provisions that will apply to the recently enacted centralized audit regime that generally assesses and collects tax at the partnership level.
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.
The regulations address disguised sales of property by or to a partnership and allocations of excess nonrecourse liabilities to partners.
A corporation may have to use the accrual method if it is required to maintain inventory records.
Including “bad boy” provisions in loan agreements is a common practice to protect the lender in the commercial real estate finance industry.
Changes in the the Bipartisan Budget Act of 2015 are a departure from how partnerships have been treated for federal income tax purposes.
The IRS issued three sets of regulations addressing issues of disguised sales of property by or to a partnership and allocations of excess nonrecourse liabilities to partners.
Recent Chief Counsel Advice provides helpful insight to taxpayers planning or negotiating merger and acquisition transactions.
The optional basis adjustment election is an attempt to allow partners to correct certain discrepancies by affecting a transferee’s allocable basis in the underlying partnership assets.
The IRS issued rules regarding the time, manner, and form for partnerships to make the election to apply the recently enacted unified partnership audit rules for certain years before Jan. 1, 2018.
The changes affect not only procedural rules and technicalities, but also the underlying economic valuation of partnership interests and legal rights of partners as well.
This item presents 10 ways that S corporations can lose their S election status, most of them involving trusts.
New regulations provide rules for determining who is the “taxpayer” for purposes of applying the Sec. 108 discharge-of-indebtedness rules to a grantor trust or disregarded entity.