Allocations of Profits & Losses

Topics

April 1, 2017

Disposing of passive activities

Disposing of property related to a passive activity does not resolve all matters related to the property.

April 1, 2017

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.

January 1, 2017

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.

May 1, 2016

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.

December 1, 2015

Calculating Basis in Debt

Direct shareholder loans to an S corporation can be very important tools for tax planning.

October 1, 2015

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.

October 1, 2013

Current Developments in S Corporations

This article discusses major changes and developments that directly affect S corporations and their tax advisers during the period of this update (July 10, 2012–July 9, 2013).

February 1, 2013

IRS Not Allowed to Reclassify Passive Activity Income

The Tax Court held the IRS could not reclassify the taxpayer’s income from the rental of cellphone towers and the land they were situated on to his wholly owned S corporation as nonpassive income under the self-rental rule.

October 1, 2012

Current Developments in S Corporations

During the period of this S corporation tax update, some major changes that directly affect S corporations took place. This article also presents tax planning ideas for S corporations and their shareholders.

March 1, 2012

The S Corporation Built-In Gains Tax: Commonly Encountered Issues

This article examines five issues corporations commonly encounter in complying with the built-in gains tax.

August 1, 2011

Separately Identifiable Intangible Assets: Tax Opportunities and Traps

Treating self-created customer-based intangibles as assets separate from goodwill can result in more favorable tax treatment for these intangibles. This article examines the rules regarding the separate treatment of self-created customer-based intangibles and the situations in which separate treatment may be beneficial.

March 1, 2011