The transaction accomplishes a distribution of assets to the parent, which may be effected in a tax-free manner only in limited circumstances.
C Corporation Income Taxation
The IRS has created an LB&I compliance campaign that affects multichannel video programming distributors and television broadcasters.
As a result of tax reform, which provides for a significant decrease in the corporate tax rate and a more modest decrease in passthrough tax rates, business owners may consider revoking S corporation elections.
The extension to March 20 applies to business taxpayers affected by the two recent winter storms, Quinn and Skylar, that primarily hit the Northeast and Mid-Atlantic United States.
Provisions relating to the repeal of the General Utilities doctrine may again face scrutiny.
SEC allows companies to use reasonable estimates of their tax liability post-tax reform.
The Bipartisan Budget Act of 2018 has many tax provisions, including retroactive extensions of a number of tax credits.
Not just large but also medium-size and even smaller companies can more easily take a RTC now that the IRS allows multiple tax years under one statistical sample study.
A new directive allows taxpayers to use R&D costs reported on FASB ASC financial statements as the starting point for computing QREs.
The IRS concluded that a taxpayer could deduct the unamortized debt-issuance costs related to its existing debt upon its exchange for new debt.
This column summarizes the federal tax law changes under reform enacted in December.
Companies may initially have difficulty determining the effects of the new federal tax law on their income tax reporting.
Safe harbor eliminates need for private letter ruling for some REIT and RIC distributions of stock and cash
The IRS established a safe harbor allowing distributions of stock to be treated as a distribution of property under Secs. 301 and 305(b) for publicly offered REITs or publicly owned RICs, as long as certain conditions are met.
Income from receipt of carbon sequestration credits relating to timberlands is qualifying REIT income
The IRS ruled it would consider income recognized by a REIT in connection with the receipt of carbon sequestration credits to be income qualifying the taxpayer to be a REIT.
Treasury and the IRS withdrew parts of proposed net value regulations that would require an exchange of net value for transactions intended to qualify under Secs. 351 and 368 and a distribution of net value for transactions intended to qualify under Sec. 332.
In some circumstances, a taxable stock sale may make more sense.
All companies should maintain supporting documentation for payments.
New regulations issued by the SEC enable individual investors to invest in startup companies through equity crowdfunding.
The tax reform bill that Congress is expected to vote on this week contains numerous changes that will affect businesses large and small.
The House of Representatives reapproved tax reform legislation on Wednesday, sending the bill to President Donald Trump for his signature.