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TOPICS / PASSTHROUGHS

S Corporation Income Taxation

S Holding Companies and F Reorgs.

In yet another in a series of F reorganization rulings, the IRS issued Letter Ruling 200701017, holding that the formation of a new corporation, followed by the contribution of S stock and an immediate qualified subchapter S subsidiary (QSub) election, will be treated as an F reorganization (i.e., a mere

Adjusting Basis of Inherited S Stock for IRD

Editor: Albert B. Ellentuck, Esq. Income in respect of a decedent (IRD) generally consists of items of gross income a decedent was entitled to at death that, because of the decedent’s method of accounting, were not included in the final individual return; see Regs. Sec. 1.691(a)-1(b). IRD is included in

TAX PRACTICE MANAGEMENT

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2025 tax software survey

AICPA members in tax practice assess how their return preparation software performed during tax season and offer insights into their procedures.

Tax Clinic

IRS generally eliminates 5% safe harbor for determining beginning of construction for wind and solar projects

IRS proposes using NAICS to determine lines of business for certain fringe benefit exclusions

IRS rules that community trust and affiliated nonprofit corporation can file a single Form 990

Prop. regs. issued on new qualified tips deduction

IRS rules for first time that REIT’s income from markup on electricity from EV charging stations is rents from real property