News & Analysis as of October 12, 2024

C-Corporation

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Income taxes are taxes that are collected on the individual earnings of persons or entities. Depending on the jurisdiction, income taxes are calculated and collected in a variety of ways. Some tax systems collect income taxes based on a progressive scheme, while others may utilize a proportional or regressive framework. less -

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

Foster Garvey PC on 6/6/2024

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

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

Stinson LLP on 12/2/2022

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

Reasonable Compensation Meets The Principal Shareholder of a C Corp

Rivkin Radler LLP on 3/11/2022

Double Tax- The shareholders of C corporations have long sought legitimate operational and transactional structures by which they may reduce the double tax hit that is realized when such a corporation distributes its...more

One Step Closer to “Building Back” – Where Do Federal Transfer Taxes Stand?

Rivkin Radler LLP on 11/23/2021

Tax the Rich? The President’s plan for a tax regime that would ensure the rich pay their “fair share” of the cost of implementing his programs has come one step closer to being realized . . . maybe . . . well, sort of ....more

[Podcast] When State Tax Agencies Speak from Both Sides of the Mouth

BakerHostetler on 3/9/2021

In Wisconsin Department of Revenue v. Deere & Company, the Department of Revenue tried to disallow a dividends received deduction for distributions from a Luxembourg entity despite published guidance conflicting with its...more

Corporate Tax Hike On The Horizon: Using Reasonable Compensation To Withdraw Value

Farrell Fritz, P.C. on 3/9/2021

Corporate Rate Increase? We begin this week with the Senate having passed the President’s $1.9 trillion coronavirus relief and economic stimulus plan (the “American Rescue Plan” following a marathon session during which...more

IRS Publishes Proposed BBA Regulations on Special Enforcement Matters

Freeman Law on 12/8/2020

Over 5 years ago, then President Obama ushered in sweeping changes to the method and manner in which partnerships are audited and partnership tax is assessed and collected through his signing of H.R. 1314, the Bipartisan...more

The Tax Court in Brief - November 2020

Freeman Law on 11/24/2020

Freeman Law’s “The Tax Court in Brief” covers every substantive Tax Court opinion, providing a weekly brief of its decisions in clear, concise prose....more

Many Federal and State Tax Deadlines Extended in Response to COVID-19 Emergency - FAQS On Guidance

Troutman Pepper on 3/27/2020

In Notice 2020-18, released on March 25, the Department of the Treasury announced that any person with a federal income tax payment or federal income tax return due on April 15, 2020 has until July 15, 2020 to make the...more

Treasury Delivers Some Good News in a Time When Good News Is Rare

Foster Garvey PC on 3/20/2020

On March 13, 2020, President Trump issued an emergency declaration, which in part instructed the U.S. Department of the Treasury (“Treasury”) to provide taxpayers with “relief from tax deadlines” due to the impact of the...more

Weekly IRS Roundup June 3 – 7, 2019

McDermott Will & Emery on 6/10/2019

Presented below is our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of June 3 – 7, 2019. June 4, 2019: The IRS issued a news release noting that it granted tax relief...more

New Tax Audit Rules May Warrant Changes to LLC and Partnership Agreements

Poyner Spruill LLP on 3/5/2019

Most partnerships and limited liability companies taxed as partnerships (collectively, "partnerships") are now in the middle of preparing their 2018 tax returns. They may notice a new line on their tax returns where they...more

Loughman Case Illustrates Potential Impact of Entity Choice on Income Tax Liability for Cannabusinesses

Rosenberg Martin Greenberg LLP on 2/22/2019

Recognition of Internal Revenue Code (“I.R.C.”) § 280E and its potential to limit deductions can have a material impact on the ongoing operation of a cannabusiness. While operational concerns require attention, improper tax...more

Bracewell Tax Report: March 2018

Bracewell LLP on 4/6/2018

The Bracewell Tax Report is a periodic publication focused on developments in federal income tax law, including the recently enacted Tax Cuts and Jobs Act (TCJA), with emphasis on how such developments impact the energy,...more

CPA Shoptalk: 8 Takeaways

Schwabe, Williamson & Wyatt PC on 1/18/2018

On January 10th, 11th and 18th our tax attorneys ?hosted a "CPA Shoptalk" seminar in ?Portland, Vancouver and Bend. Below are ?some key takeaways to consider... 1. Partnership Audit Rules Post-TEFRA - The Balanced...more

Transferee Liability: The [Unlikely] Situation that your Nonprofit Receives a Charitable Gift with Expensive Tax Strings Attached

Coblentz Patch Duffy & Bass on 10/12/2016

The case of Salus Mundi Foundation et al v. Commissioner - On August 15, 2016, the Tax Court decided in Salus Mundi Foundation et al v. Commissioner, T.C. Memo. 2016-154, that two foundations were liable as transferees...more

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