S Corporation Income Taxation

TOPICS / PASSTHROUGHS

December 1, 2017

Structuring loans for S corp. shareholder basis planning opportunities

An understanding of S corporation basis rules enables practitioners to assist clients in taking advantage of planning opportunities aimed at maximizing deductible passthrough losses.

November 1, 2017

Liability for payment of employment taxes when using a PEO

Chief Counsel Advice was issued regarding who is ultimately liable for payment of employment taxes when using a professional employment organization.

September 1, 2017

Tax Court allows full meal deduction for NHL team’s away games

Pregame meals provided to Boston Bruins players and personnel before away games qualify as a de minimis fringe benefit.

August 1, 2017

Allocating S corp. losses to acquiring and terminating shareholders

An S corporation’s election to use specific accounting can alter the allocation of passthrough items in some cases.

August 1, 2017

The importance of tracking AAA and E&P in transactions involving S corps.

Tracking these accounts is important if an S corporation enters into certain transactions such as redemptions, liquidations, reorganizations, or corporate separations.

June 27, 2017

Boston Bruins can deduct full cost of meals for team’s away games

The Tax Court held that the owners of the Boston Bruins could deduct the full cost of their team’s pregame meals for away games as a de minimis fringe benefit.

May 1, 2017

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.

May 1, 2017

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.

April 6, 2017

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.

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.

April 1, 2017

Disposing of passive activities

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

March 1, 2017

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.

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.

December 1, 2016