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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

Holland & Knight LLP

Condemned to Lose Your ADIT?

Holland & Knight LLP on

In a private letter ruling, the IRS concluded that the condemnation of public utility property is in effect a "retirement" or "disposition" that requires the elimination of accumulated deferred income taxes (ADIT) associated...more

Eversheds Sutherland (US) LLP

IRS rules no violation of normalization requirements in computation of pro rata portion of ADIT used to reduce rate base

In a recent private letter ruling (PLR 201949006), the Internal Revenue Service (IRS) addressed the computation of the pro rata portion of accumulated deferred federal income tax reserve (ADFIT, together with the total...more

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