News & Analysis as of

Tax Liability C-Corporation

Alston & Bird

Supreme Court Holding Adds Complexity to Estate Planning

Alston & Bird on

Keeping it in the family just got more complicated. Our Tax Group studies a Supreme Court decision that left a family with an unexpected estate tax liability related to a share redemption agreement....more

Rivkin Radler LLP

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

Rivkin Radler LLP on

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 –...

Foster Garvey PC on

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

Bilzin Sumberg

Final Treasury Regulations Implement a 10-Year Transition Rule for Existing Domestically Controlled REITs

Bilzin Sumberg on

The U.S. Department of the Treasury (the “Treasury”) and the Internal Revenue Service (the “IRS”) have recently issued final regulations (the “Final Regulations”) that significantly impact the determination of whether a real...more

Rivkin Radler LLP

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

Rivkin Radler LLP on

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

Rivkin Radler LLP

ESBTs and the Carryover of S Corporation Losses

Rivkin Radler LLP on

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

Wyrick Robbins Yates & Ponton LLP

Decoding Entity Selection: Considerations for Founders

What’s the Best Choice of Entity? When we work with founders to start their business, the question of which type of entity to form is often their first question. For many high-growth companies that are planning to obtain...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

Stinson LLP

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

Stinson LLP on

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

Private Foundations, Closely Held Businesses, And Distribution Requirements

Rivkin Radler LLP on

“Show Me the Money”- Much has been written in recent months about how well the investment portfolios of private foundations have performed over the last several years. For example, a study conducted by the Council on...more

Rivkin Radler LLP

Planning for the Interest Charge on Installment Sales: Decanting a Grantor Trust?

Rivkin Radler LLP on

I recently encountered an interesting situation in which someone suggested that a grantor trust be decanted into a non-grantor trust before the end of the taxable year. The reason? To avoid the special interest charge that...more

Rivkin Radler LLP

Reasonable Compensation Meets The Principal Shareholder of a C Corp

Rivkin Radler LLP on

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

Rivkin Radler LLP

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

Rivkin Radler LLP on

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

Harris Beach PLLC

Why Cannabis Related Businesses Must Consider Legal and Tax Issues

Harris Beach PLLC on

As cannabis related businesses (CRBs) seek strong corporate foundations for business success in a rapidly shifting landscape, it’s critical to consider strategy related to legal and tax issues. Wesley Rene, an attorney on our...more

Cozen O'Connor

House Ways and Means Committee Proposes Reduction of QSBS Exclusion

Cozen O'Connor on

On September 15, 2021, the House Ways and Means Committee approved its draft tax legislation that was released on September 13, 2021, as part of the “Build Back Better” budget reconciliation program. Included in the draft...more

BakerHostetler

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

BakerHostetler on

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

Farrell Fritz, P.C.

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

Farrell Fritz, P.C. on

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

Freeman Law

IRS Publishes Proposed BBA Regulations on Special Enforcement Matters

Freeman Law on

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

Freeman Law

The Tax Court in Brief - November 2020

Freeman Law on

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

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

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

Poyner Spruill LLP

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

Poyner Spruill LLP on

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

Rosenberg Martin Greenberg LLP

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

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

Whitman Legal Solutions, LLC

If One Musician Plays A Wrong Note, the Entire Orchestra Now May Pay the Price -- Be Aware of New Partnership Tax Audit Rules

In 1985, the “participatory journalist” George Plimpton worked as a temporary percussionist, playing sleigh bells, triangle, bass drum, and most notably, gong, with the New York Philharmonic. During a performance, he once...more

34 Results
 / 
View per page
Page: of 2

"My best business intelligence, in one easy email…"

Your first step to building a free, personalized, morning email brief covering pertinent authors and topics on JD Supra:
*By using the service, you signify your acceptance of JD Supra's Privacy Policy.
- hide
- hide