With the increased use of stock acquisitions, buyers must correctly apply the Sec. 382 limitations, including the additional analysis to determine the impact of NUBIG and NUBIL.
Gains & Losses
Tax treatment of individual owners of bitcoin and other virtual currencies held for personal use or investment
Tax preparers will need to be proactive in helping their clients identify and report any potentially taxable transactions.
The owner of a hotel and restaurant complex was not entitled to capital gains treatment under Sec. 1234A for a deposit it retained after a would-be buyer terminated a contract to purchase the complex.
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.
The House tax reform bill contains a large number of proposed changes that would affect businesses.
The Tax Court considered whether redemption of phantom stock was a sale of a capital asset and what the tax basis in the redeemed phantom stock was.
The House Blueprint, if enacted, may provide incentives for certain taxpayers to merge in the future.
This item presents an opportunity to minimize the tax impact of a distribution by a closely held corporation that is not made out of the corporation’s E&P.
This item focuses on stock redemptions, or transactions having the effect of a redemption, causing an ownership change.
This item provides a brief history of existing tax law in this area and IRS guidance and a summary of the recent developments.
A taxpayer was not entitled to defer gain on a disposition of property to a related party that met the Sec. 1031(a) requirements for a like-kind exchange.
Ascertaining the Tax Impact on the Shareholder of a Corporate Assumption of Liabilities in a Sec. 351 Transfer
The transfer of debt to a corporation will create a taxable event in some situations.
Temporary and proposed regulations implement the amendments to the real estate investment trust spinoff rules.
This item examines the potential application of Sec. 304 to transfers of interests in a partnership that owns corporate stock.
Foreign currency straddles may be used to manage foreign currency exposure, but they may carry hidden tax issues.
The IRS issued final rules that prevent taxpayers from transferring losses to corporations.
The Tax Court discussed the application of the “boot” rules under Sec. 356 in a tax-free reorganization.
The Internal Revenue Service finalized rules that limit the ability of a taxpayer to transfer loss property to a corporation.
Selling off and replacing assets could result in a possible taxable gain. A common business practice for avoiding such a gain is to engage in a Sec. 1031 exchange.
Proposed Regulations Would Provide Guidance for Allocation and Absorption of Losses on a Consolidated Return
Proposed regulations address an issue when there is a consolidated net operating loss.