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Internal Revenue Service Tax Planning C-Corporation

The United States Internal Revenue Service is a bureau of the United States Department of the Treasury. The IRS is charged with collecting revenue and enforcing the Internal Revenue Code.  
Holland & Knight LLP

Tax Planning Prevails in Parkway Gravel Decision

Holland & Knight LLP on

The U.S. Tax Court recently issued an opinion in Parkway Gravel Inc. v. Commissioner, Docket No. 10819-21, respecting the structure of a gravel company's sale of a land parcel known as the Freeway Pit. In finding for the...more

Kaufman & Canoles

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

Kaufman & Canoles on

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

DarrowEverett LLP on

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

Foster Garvey PC

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

Foster Garvey PC on

In October 2023, I authored a new White Paper, A Journey Through Subchapter S / A Review of The Not So Obvious & The Many Traps That Exist For The Unwary. This year, in a multi-part article, I intend to take our blog...more

WilmerHale

State Taxation of Qualified Small Business Stock: Federal Tax Exclusion Not Always Replicated at State Level

WilmerHale on

In the event of an M&A transaction, many stockholders plan to take advantage of the exclusion from federal taxable income of gain realized from the sale or exchange of “qualified small business stock” (QSB stock). Section...more

Dickinson Wright

Care and Feeding of Practice Entities to Avoid Federal Tax Issues

Dickinson Wright on

In prior articles in this publication, this author addressed a federal tax issue faced by practice entities- the possible attack by the Internal Revenue Service (IRS) on a common practice of incorporated medical and other...more

Greenberg Glusker LLP

Harry Potter and the Chamber of Secret QSBS Exclusions

Greenberg Glusker LLP on

Are your shareholders leaving money on the table? Certain tax planning strategies, much like magic spells in the Wizarding World of Harry Potter, require some pre-ordained incantations in order to bring them to life. The...more

Rivkin Radler LLP

Constructive Dividends and The Closely Held C Corporation

Rivkin Radler LLP on

Withdrawing Value- Any tax adviser who has represented closely held businesses and their owners long enough realizes there are certain recurring themes that transcend the otherwise unique characteristics of the industry of...more

Faegre Drinker Biddle & Reath LLP

Selling an LLC? Don’t Forget About 280G!

Internal Revenue Code Section 280G (280G) (commonly referred to as the golden parachute provision) is intended to discourage the payment of excessive compensation to certain shareholders, officers and highly compensated...more

Smith Anderson

Gain Without Pain: Qualified Small Business Stock and Section 1202 of the Internal Revenue Code

Smith Anderson on

With the prospect of an increase in capital gain income tax rates looming on the horizon, what could be more welcome than an exclusion of 100% of gain from income? That is exactly what Section 1202 of the Internal Revenue...more

Polsinelli

Additional Guidance Issued for President Biden’s American Jobs and American Families Plan

Polsinelli on

In April 2021, President Biden announced the “American Families Plan,” which included some significant tax law changes. Among the proposed changes included in the “American Families Plan” was the increase of the tax rate that...more

Gerald Nowotny - Law Office of Gerald R....

THE ACCIDENTAL ENTREPRENEUR

Episode #22 The Accidental Entrepreneur - The Optimal Corporate Set Up discusses the virtues and financial powers of creating your own business as a vehicle for ensuring your current and future financial stability. Consider...more

Gerald Nowotny - Law Office of Gerald R....

The Accidental Entrepreneur - Part II The Optimal Corporate Set Up

In April 2016, I wrote Part One of this series. You can read this article on JD Supra. Part One focused on the hobby loss tax rules. Four years later I am writing part two. Did I forget that I had written part one? Perhaps!...more

Farrell Fritz, P.C.

Responding To The Democratic Party’s Tax Plans

Farrell Fritz, P.C. on

The Convention- The Democratic Party’s “virtual” convention last week seems to have gone pretty well. All the stars of the Party’s firmament were on hand and spoke in “virtually” one voice in their assessment of the...more

Troutman Pepper

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

Troutman Pepper on

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

Foster Garvey PC

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

Foster Garvey PC on

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

Bradley Arant Boult Cummings LLP

IRS Provides Additional Clarity Regarding Donations to Scholarship Granting Organizations - SALT Alert: Alabama Edition

On December 16, the Internal Revenue Service (IRS) and the Treasury Department issued proposed regulations... that provide some good news and needed clarification for C corporations, individuals, and S corporations and other...more

Bradley Arant Boult Cummings LLP

Treasury Department Issues Final Regulations Limiting Charitable Deductions – Potential Impact on Alabama Donors? - SALT Alert:...

Now that the dust has settled following the issuance of the final “SALT cap workaround” regulations by the Treasury Department, here’s a summary of those regulations, the IRS guidance issued in connection with the final...more

McDermott Will & Emery

Weekly IRS Roundup June 3 – 7, 2019

McDermott Will & Emery on

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

Troutman Pepper

Structuring U.S. Debt Facilities in Light of New IRS Rules

Troutman Pepper on

Until recently, the structuring of debt facilities for U.S. borrowers with foreign subsidiaries has been largely driven by IRS interpretations of section 956 of the Internal Revenue Code, which gave rise to significant tax...more

Bradley Arant Boult Cummings LLP

Status Report on IRS Guidance Limiting Charitable Contribution Deductions to Scholarship Granting Organizations - SALT Alert:...

Sometimes the law of unintended consequences is difficult to correct after the fact. The most recent example may be the 2017 Tax Cuts and Jobs Act’s $10,000 annual limitation on state and local tax deductions claimed by...more

Bowditch & Dewey

Op Funds Expand Deferral Paths for CRE Investors

Bowditch & Dewey on

BOSTON — The Tax Cuts and Jobs Act of 2017 created the Opportunity Zone program which provides real estate investors a new tool to defer gains from sales or exchanges of capital assets by investing those gains in a “Qualified...more

Proskauer - Tax Talks

U.S. Tax Reform: IRS Proposes Interest Deduction Limitation Regulations

Proskauer - Tax Talks on

On November 26, 2018, the Internal Revenue Service (the “IRS”) and the U.S. Department of the Treasury (the “Treasury”) issued proposed regulations (the “Proposed Regulations”) under section 163(j) of the Internal Revenue...more

Williams Mullen

IRS Gets “Bageled” in Tax Court Over Family Office Expenses

Williams Mullen on

A recent case, Lender Management LLC v. Commissioner of Internal Revenue, T.C. Memo. 2017-246, has created a window of opportunity for family offices to restructure their affairs and potentially deduct certain family office...more

Fenwick & West LLP

Impact of Tax Reform on the Purchase and Sale of Controlled Foreign Corporations — Selected Considerations

Fenwick & West LLP on

The application of §1248 and §338(g) in the context of the purchase or sale of a controlled foreign corporation (CFC) has long been one of the most complex areas of the tax code. The recently enacted tax reform act — herein,...more

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