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.
Meeting the active trade or business requirement is critical to ensuring a corporation leasing farmland qualifies for a tax-free divisive reorganization.
Cooperative corporations can shield net income from taxation by returning it to the patrons in the form of qualified patronage dividends.
This column discusses whether fuel blending may be
treated as a domestic production activity for purposes of the DPAD deduction.
Taxpayers who have engaged in “micro-captive transactions,” which the Internal Revenue Service has designated as transactions of interest, have until May 1 to file the required disclosure statement.
Fifth Circuit vacated Tax Court’s decision that MoneyGram International Inc. was not a bank because the Tax Court applied incorrect definitions
of “deposits” and “loans.”
The IRS determined a taxpayer’s substantial renovation, construction, and erection of certain
property qualified as the construction of real property under Sec. 199.
These transfers are considered a nontaxable contribution of capital by a nonshareholder to the utility.
There have been recent changes to the eligibility requirements for certain small captives to elect to be taxed only on their investment income.
A recharacterization of royalties as income tax in some countries results in a high rate of foreign tax imposed on foreign oil and gas income that can be creditable against the U.S. tax.
The CCF program helps owners and operators of
U.S. flag vessels accumulate capital to modernize and expand the U.S. merchant marine.
Recent tax developments relating to captive insurance companies present potential new opportunities for some captive arrangements while raising caution about others. This item highlights current, practical considerations regarding qualification of a captive as an insurance company for federal income tax purposes.
This item focuses specifically on the implications for satisfying the "risk distribution" requirement for having a valid captive insurance arrangement.
Pharmaceutical companies confront several tax differences when determining whether a transaction is a license or sale.
Captive insurance is an alternative form of risk management that is becoming a more practical and popular means through which companies can protect themselves financially while having more control over how they are insured.
Tax Court upheld deductions for insurance premiums paid by a parent company's wholly owned subsidiaries to another wholly owned captive insurance subsidiary.
This article examines income tax issues that commonly arise in connection with the conveyance of pipeline easements and surface sites and identifies planning opportunities.
The Court of Federal Claims denied approximately $1.6 billion in cost basis related to decommissioning liabilities assumed in connection with the purchase of three nuclear power plants.
The final and reproposed tangible property regulations will significantly affect the oil and gas industry. Specifically, the unit-of-property determination has different implications for oil and gas companies, depending on which segment the companies operate in.
Under Sec. 631(b), gains or losses from the sale of standing timber are considered gains and/or losses from the sale of business use property.