News & Analysis as of

C-Corporation Internal Revenue Code (IRC) Income Taxes

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...

Foster Garvey PC on

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

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

King & Spalding

Treasury Issues Final Regulations Addressing “Domestically Controlled” REIT Status

King & Spalding on

On April 25, 2024, the IRS and Treasury issued final regulations (the “Final Regulations”) addressing whether a real estate investment trust (a “REIT”) or a regulated investment company (a “RIC”) will constitute a...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

Holland & Knight LLP

Commuting Disallowance in 274(l) Does Not Apply to Partners, 2% Shareholders in S Corporations

Holland & Knight LLP on

Beginning in 2018, Internal Revenue Code (I.R.C.) Section 274(l) disallows deductions for the cost of flights provided to an "employee" for commuting. While this deduction disallowance may apply to employees of Subchapter C...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

Freeman Law

Qualified Small Business Stock: One of the Code’s Most Significant (And Often Overlooked) Tax Breaks

Freeman Law on

Section 1202 offers a once little-known exclusion from income for gain on qualified small business stock (“QSB stock”). The provision has undergone substantial revisions over the years and came back into vogue as a result of...more

Polsinelli

The House Ways and Means Committee Finally Provides Draft Legislative Language for the Tax Changes First Set Forth in President...

Polsinelli on

In April 2021, President Biden announced the “American Families Plan,” which included some significant tax law changes. On May 28, 2021, the United State Department of Treasury issued a report entitled “General Explanation of...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

Bradley Arant Boult Cummings LLP

ADOR Affirms Deductibility of PPP Loan-Related Expenses but Unanswered Conformity Questions Remain

The Alabama Department of Revenue issued helpful guidance on January 7, following its December 18, 2020 guidance implementing Governor Ivey’s landmark Supplemental Emergency Proclamation. The new guidance affirms the...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

Perkins Coie

IRS Announces Delay of Certain Periods for 1031 Transactions

Perkins Coie on

In response to the ongoing coronavirus pandemic (COVID-19), the Internal Revenue Service (the IRS) has taken additional actions intended to provide immediate relief to taxpayers. Delay of Identification and Acquisition...more

Foley & Lardner LLP

IRS Issues Guidance Regarding Net Operating Loss Carryback Waivers and Refunds Under the CARES Act | Blogs | Coronavirus Resource...

Foley & Lardner LLP on

On April 9, 2020, the IRS issued: Rev. Proc. 2020-24, which provides guidance under the Coronavirus Aid, Relief, and Economic Security Act (CARES Act) relating to relinquishment of certain net operating loss (NOL)...more

Seyfarth Shaw LLP

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

Seyfarth Shaw LLP on

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

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

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

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

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

Bradley Arant Boult Cummings LLP

Summary of Newly Released ADOR Analysis of Federal Tax Reform's Impact on Alabama Income Tax Laws - SALT Alert: Alabama Edition

On July 31, the Alabama Department of Revenue (ADOR) released its long-awaited “Analysis of Federal Tax Law Revisions on the State of Alabama,” a comprehensive review of the changes brought about by the Tax Cuts and Jobs Act...more

Burr & Forman

The New Section 199A 20% “Profit Deduction” for Pass-Through Businesses: The Undecided Issue of Owner Compensation

Burr & Forman on

Under the Tax Cuts and Jobs Act, Congress is now offering a new 20% deduction for “pass-through” businesses – i.e. businesses that are not corporations. With the corporate tax rate being reduced under the new law to a flat...more

Foster Garvey PC

Decoding the Tax Cuts and Jobs Act – Part V: Changes to IRC §163(j) and the Business Interest Deduction Rules

Foster Garvey PC on

“Neither a borrower nor a lender be...” or at least, if you insist on borrowing (and we understand the appeal), we are here to help you stay abreast of the new rules on deducting interest. BACKGROUND/PRIOR LAW - Interest...more

Foster Garvey PC

Decoding the Tax Cuts and Jobs Act – Part IV: The IRC § 199A Deduction for Qualified Business Income—the Devil Is in the Details...

Foster Garvey PC on

BACKGROUND - The Tax Cuts and Jobs Act (“TCJA”) adopted a new 20% deduction for non-corporate taxpayers. It only applies to “qualified business income.” The deduction, sometimes called the “pass-through deduction,” is...more

32 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