The Tax Court’s decision in Estate of Bartell alleviates uncertainty about structuring
a reverse like-kind exchange intended to qualify for nonrecognition treatment.
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TOPICS / PASSTHROUGHS
S Corporation Income Taxation
S corporation owner-employees: Who controls income?
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.
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.
Failure to Use S Corporation Correctly Results in Self-Employment Tax
Income earned by financial adviser was his, not the income of his wholly owned S corporation, and was therefore subject to self-employment tax.
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.
Avoiding Conversion to the Accrual Accounting Method by Electing S Status
A corporation may have to use the accrual
method if it is required to maintain inventory records.
Asset Acquisition Target Ineligible for Success-Based Fee Safe Harbor
Recent Chief Counsel Advice provides helpful insight to taxpayers planning or negotiating merger and
acquisition transactions.
Top 10 Easy Ways That Trusts Cause Loss of S Corporation Status
This item presents 10 ways that S corporations
can lose their S election status, most of them involving trusts.
Documenting Deductible Transaction Costs for Acquisitive Transactions
This item discusses the ability of a target in a Sec. 338(h)(10) transaction to use the safe-harbor election provided by Rev. Proc.
2011-29.
Ordinary Deduction for Worthless QSub Stock
Restructuring an existing QSub in an attempt to qualify for an ordinary deduction is prohibited and might result in an unfavorable deferral of loss.
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.
Life Insurance and S Corporations: Unique Rules Present Opportunity and Peril
This column outlines the special considerations and issues related to life insurance policies for S Corporations.
Calculating Basis in Debt
Direct shareholder loans to an S corporation can be very important tools for tax planning.
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.
Is It Rent? That Depends on the Lease
A recent Tax Court decision sheds light on the importance of lease terms to determine what is rent and how Sec. 467 may apply to advance rents.
Tax Considerations for Cancellation-of-Debt Income
This item provides an overview of the U.S. income tax implications of cancellation-of-debt income that results from bankruptcy or insolvency, with a focus on the differences in the tax treatment for C corporations, S corporations, and partnerships.
The Importance of Being Flexible: Choice-of-Entity Considerations
This item presents an overview of some of the tax points that should be kept in mind when choosing an entity.
IRS Clarifies That a Former QSub Cannot Prorate Post-Termination Items of Income or Loss
IRS addressed whether an S corporation and its wholly owned subsidiary, a QSub, must prorate annual income following a midyear voluntary revocation of subchapter S election.
The Transfer of Loss Property Between an S Corporation and Its Shareholders
S corporations and their shareholders often engage in transactions in which they transfer property with a basis greater than its FMV. This article examines the tax effects on both shareholders and the corporation.
TAX PRACTICE MANAGEMENT
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.
