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C-Corporation Shareholders S-Corporation

Husch Blackwell LLP

Pouring Over Options: Corporate Structures for Functional Beverage Brands

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Whether at 7-11 or at your local grocery chain, functional beverages line the aisles, touting their nutritional and health benefits. The functional beverage industry is becoming big business, but as this industry bubbles up,...more

Mintz - Tax Viewpoints

F-Reorgs: How Buyers’ and Sellers’ Favorite ‘F Word’ Optimizes M&A and Private Equity Transactions Involving S Corporations

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In M&A and private equity transactions, buyers and sellers are consistently looking for ways to maximize value, which requires a critical focus on structuring the transaction in a tax-efficient manner. This pursuit of tax...more

Foster Garvey PC

A Journey Through Subchapter S / A Review of The Not So Obvious & The Many Traps That Exist For The Unwary: Part X – Converting a...

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When considering converting a C corporation to an S corporation, tax advisers and taxpayers need to pay careful attention to the many perils that exist. Failure to pay close attention to the road in this area could result in...more

Levenfeld Pearlstein, LLC

“It’s Not Business, It’s Personal”: The Application of Personal Goodwill in Accounting Firm Deals

Personal goodwill refers to the reputation, relationships, and other intangible assets directly attributable to an individual professional rather than the business entity itself. It is especially relevant for professional...more

Rivkin Radler LLP

The Supreme Court’s Non-Opinion On The “Realization” of Income – A Lost Opportunity?

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In less than four months, the citizens of the United States will be electing their next President to a four-year term. They will also be deciding which of the two major political parties will “control” the Senate, the House,...more

Foster Garvey PC

A Journey Through Subchapter S / A Review of The Not So Obvious & The Many Traps That Exist For The Unwary: Part VII –...

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In the S corporation arena, tax advisors generally do not focus much attention on unreasonable compensation. As we delve into the issue in this Part VII of my multi-part series on Subchapter S, it will become apparent that...more

Kaufman & Canoles

Section 1202 QSBS - The Overlooked Arrow in the Business Succession Quiver

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Business owners considering exit options from their businesses often can be blinded by purchase price figures and proceeds, often “accepting” that paying capital gains tax is part of the deal. The ability to avoid or defer...more

DarrowEverett LLP

Accidental Termination on Purpose? S Corp Ruling Could Be Huge For QSBS Owners

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Qualified Small Business Stock (“QSBS”) is arguably one of the largest “gifts” Congress has given taxpayers by excluding from a shareholder’s gross income the greater of $10 million or 10 times the shareholder’s basis in the...more

Rivkin Radler LLP

Debtor Corp’s S Election: “Property” in Bankruptcy?

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Uncertain Future- The Congressional Budget Office (“CBO”) recently released some data for the federal government’s 2023 fiscal year. According to the CBO, the federal budget deficit for the year was $1.7 trillion, or...more

Ward and Smith, P.A.

Purchases and Sales of an Incorporated Business: Asset Acquisitions and Stock Sales

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There are two primary ways to structure the taxable purchase and sale of an incorporated business.  The parties may engage in an asset acquisition, in which the buyer purchases assets directly from the target corporation....more

Rivkin Radler LLP

ESBTs and the Carryover of S Corporation Losses

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Since 1995 to the present, the LLC has emerged as the entity of choice for the vast majority of entrepreneurs. This form of business entity owes its success to the flexibility and to the tax benefits that it affords its...more

Stinson LLP

Owners of a Corporation Pay the Corporation's Expenses; Can Such Expenses be Deducted by the Owners?

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As a general rule, a corporation is considered a separate entity from its owner(s). There are a few cases in which a corporate entity is disregarded as an entity separate from its owners, such as when a corporation is set up...more

Rivkin Radler LLP

Business Expenses Paid by Shareholder, But Whose Deduction Is It?

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Constructive Transfers- It is axiomatic that the tax treatment of interactions between a closely held business and its owners will generally be subject to heightened scrutiny by the IRS, and that the labels attached to such...more

Holland & Hart - The Benefits Dial

Take A Chance On Me? Could We Finally See Legislation Expanding Section 1042 Deferral to S Corp ESOPS?

One of the most popular incentives for small business owners to establish an ESOP (employee stock ownership plan) is the ability to defer tax on the gain they will receive in the sale through the Section 1042 deferral. If...more

Rivkin Radler LLP

Selling Your S Corporation’s Business? What If It’s Not an S Corporation?

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Haste Makes Waste? How many of you are suffering from Build Back Better Fatigue? Seriously, it’s a thing. Sure, the House passed its version of the President’s tax and spending bill on November 19, and the Senate...more

Rivkin Radler LLP

Maybe Tax the Rich, but Not The Conversion of S corps into Partnerships – What Gives?

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Tax the Rich? A few days ago, an opinion piece that appeared in the Wall Street Journal began as follows: “President Biden’s effort to pass the largest tax increase in U.S. history is based on the verifiably false...more

Rivkin Radler LLP

Disposing Of Assets Under The Ways and Means Committee’s Proposals

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First Step- Last Wednesday, the House Ways and Means Committee approved that portion of the 2022 budget legislation with which it was tasked by the Congressional Budget resolution of August 24. The text of the bill...more

Robins Kaplan LLP

The Robins Kaplan Spotlight, Vol. 6 No. 2, Spring 2021 - In the Beginning: Choosing the Right Corporate Entity

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Professionals have a wide range of corporate entities to choose from when setting up their businesses, such as corporations, limited liability companies (LLCs), limited liability partnerships, limited partnerships, general...more

Rivkin Radler LLP

Partners, S Corp. Shareholders And Biden’s 2022 Revenue Proposal: No More Business As Usual

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What A Ride- No one anticipated that the Administration’s proposed tax increases would fly through Congress easily – at least no one residing in a state in which the recreational use of marijuana has not been legalized....more

Rivkin Radler LLP

“Opaque Income Sources” + “Tax Gap” = More Enforcement + Tax Hikes = Anyone’s Guess

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Tax Gap- In a report released last week, the U.S. Treasury Department explained that the so-called “tax gap” – i.e., the difference between the amount of federal income taxes owed by taxpayers for a taxable year and the...more

McDermott Will & Emery

Weekly IRS Roundup September 14 – September 18, 2020

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Presented below is our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of September 14, 2020 – September 18, 2020... September 14, 2020: The IRS published final...more

Hinshaw & Culbertson LLP

New Interim PPP Rules Address Owner-Employee Compensation, Sub-Tenants, and Rent Payments to a Related Party

The Small Business Administration (SBA) and the U.S. Department of the Treasury issued a new interim Paycheck Protection Program (PPP) rule on August 24, 2020. The rule covers changes involving owner-employee compensation,...more

Farrell Fritz, P.C.

An S Corporation In New York City: Eschew Obfuscation – Or Not

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NYC: A “Helluva” Town, for S corps- Of late, I’ve received a surprising number of inquiries regarding the taxation of S corporations doing business in New York City (“NYC”). As many of you know, NYC does not recognize...more

Pillsbury Winthrop Shaw Pittman LLP

Benefit Corporations and B Corps Among Options For Startups Seeking To Do Good

Added legal protection and potential marketing benefits make benefit corporations and B Corps a great fit for certain entrepreneurs and industries. But interested parties should carefully consider all details before jumping...more

Seyfarth Shaw LLP

An Electing Real Property Trade or Business can Revoke its Election on Account of the Change to Qualified Improvement Property...

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On April 10, 2020, the Internal Revenue Service (the “IRS”) issued Revenue Procedure 2020-22 (the “Revenue Procedure”), which (1) permits an “electing real property trade or business” that elected not to be subject to the...more

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