The Tax Court’s decision in Estate of Bartell alleviates uncertainty about structuring a reverse like-kind exchange intended to qualify for nonrecognition treatment.
S Corporation Income Taxation
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.
Disposing of property related to a passive activity does not resolve all matters related to the property.
This item discusses whether S corporations should be entitled to an ordinary loss under Sec. 165(g)(3) as a matter of law.
Income earned by financial adviser was his, not the income of his wholly owned S corporation, and was therefore subject to self-employment tax.
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.
A corporation may have to use the accrual method if it is required to maintain inventory records.
Recent Chief Counsel Advice provides helpful insight to taxpayers planning or negotiating merger and acquisition transactions.
This item presents 10 ways that S corporations can lose their S election status, most of them involving trusts.
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.
Restructuring an existing QSub in an attempt to qualify for an ordinary deduction is prohibited and might result in an unfavorable deferral of loss.
The potential effect of the built-in-gain tax is often a significant consideration during pending acquisitions involving an S corporation.
Taxing authorities have sought to incorporate adequate lead time into the tax filing process.
This column outlines the special considerations and issues related to life insurance policies for S Corporations.
Direct shareholder loans to an S corporation can be very important tools for tax planning.
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.
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.
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.
This item presents an overview of some of the tax points that should be kept in mind when choosing an entity.
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.