News & Analysis as of

Corporate Taxes Internal Revenue Service

Getting Something for Nothing: IRS Withdraws Proposed “Net Value” Regulations

In June 2005, the Internal Revenue Service (IRS) issued a package of proposed regulations providing that certain corporate liquidations, formations and reorganizations would not qualify for nonrecognition treatment if the...more

Good News for Taxpayers: IRS Targets for Reform Burdensome Regulations on Partnerships, Corporations, REITs, Estates, and More

Earlier this year, President Trump issued Executive Order 13789, which ordered the Treasury Department to review all significant tax regulations issued after December 31, 2015 and identify regulations that impose an undue...more

Entity Selection Series | Part Three: The Benefits of an S-Corporation

In Part One and Part Two of the Entity Selection Series, we discussed the benefits of a Limited Liability Company and a C-Corporation for organizing a venture business. In this edition, we will discuss the benefits (and...more

IRS Identifies 8 Burdensome Regulations for Reform

Responding to a Trump Executive Order, the Treasury Department has reviewed all significant tax regulations issued after December 31, 2015 and identified eight regulations to be reformed to mitigate the burden that the...more

IRS Can Pursue “Responsible Persons” for Unpaid Trust Fund Taxes and Automatic Stay Cannot Be Used to Enjoin Collection Against...

The Puerto Rico Bankruptcy Court followed the Third Circuit in holding that the Anti-Injunction Act, which prohibits suits to restrain the assessment or collection of any tax, is not superseded by section 105(a) of the...more

IRS Announces Tax Audit Targets

Over the past several years, IRS has reduced the number of its tax auditors by about 25 percent – from just over 12,000 tax auditors in 2011 to about 9,000 tax auditors in 2015. This staffing reduction has forced IRS to focus...more

Funds Talk: June 2017 - The IRS Resumes Issuing Private Letter Rulings on ‘Leveraged’ and ‘North-South’ Spinoffs

The IRS announced in May that it will resume issuing private letter rulings (PLRs) on two types of spinoff transactions — leveraged spinoffs and north-south spinoffs — that had been on its “no-rule” list since 2013. In a...more

Internal Revenue Service Announces It Will Recommence Issuing Private Letter Rulings on Certain Spin-Off Debt Exchanges

by Shearman & Sterling LLP on

The Internal Revenue Service has announced that it will recommence issuing private letter rulings concerning whether a distributing corporation’s transfer of stock or securities of a controlled corporation (or “Spinco”) in...more

IRS Issues Guidance on "North-South" Transactions

On May 3, 2017, the IRS released Revenue Ruling 2017-9, which addresses two so-called "north-south" transactions in connection with spin-offs that are intended to be nontaxable under Section 355 of the Internal Revenue Code....more

S-Corps, Basis & Loss Limitations

by Farrell Fritz, P.C. on

In General- It is a basic principle of federal tax law that a taxpayer cannot, for purposes of determining the taxpayer’s taxable income, claim a loss with respect to an investment in excess of the taxpayer’s unrecovered...more

Fourth Circuit Economic Substance Doctrine

by Alston & Bird on

The Tax Court’s recent opinion in Austin v. Commissioner, TC Memo 2017-69, claims to be following the Fourth Circuit’s view of the economic substance doctrine by calling it the sham transaction doctrine, saying it is an issue...more

Audit Chances

by Pessin Katz Law, P.A. on

As in the past, PK Law reports on the Internal Revenue Service’s (“IRS”) data book (IR 2017-69) regarding a taxpayer’s chances of undergoing an audit. The annual data book reflects data collected during the fiscal year 2016...more

IRS Releases Updated Automatic Changes in Methods of Accounting List

On April 19, 2017, the Internal Revenue Service (IRS) released Rev. Proc. 2017-30, 2017-17 I.R.B. 1, which provides an updated list of automatic changes in methods of accounting. As was the case with its predecessor, Rev....more

For High-Income and International Taxpayers: Defensive Tax Planning

The Importance of Defensive Tax Planning - IRS audit criteria target high-income taxpayers, especially those with reported foreign income or foreign financial assets. Targeted high income taxpayers include...more

March Madness: New Private Letter Rulings Address Tax Accounting Issues

In the last few weeks, the Internal Revenue Service (the Service) issued several private letter rulings addressing a variety of tax accounting issues. From bonus depreciation elections to the correct unit of property for...more

"Key Takeaways: Lessons Learned From Tax-Related Whistleblower Litigation and Shareholder Actions"

On March 8, 2017, Skadden hosted a webinar titled “Lessons Learned From Tax-Related Whistleblower Litigation and Shareholder Actions.” The Skadden panelists were tax partners Nathaniel Carden and Armando Gomez, and litigation...more

Are you paying your children too much to work in the family business? The IRS might think so.

by Murtha Cullina on

A United States Tax Court recently issued a decision after trial that should serve as a reminder to management and controlling shareholders of family-owned businesses that salaries or other compensation paid to family-member...more

New Partnership and Corporate Tax Return Filing Dates Now in Effect

As I previously discussed, the federal tax due date for partnership and corporate tax returns changed for tax years on or after 2016. This means that the new filing deadlines are now in effect. Partnership and S corporation...more

New Tax Filing Deadlines Affect Unsuspecting LLCs and Partnerships For 2017

Several tax bills passed by Congress late in 2015 changed the deadlines for filing federal income tax returns for partnerships and most limited liability companies, which are treated as partnerships for tax purposes. Other...more

LB&I to Closely Scrutinize Basket Transactions

The Large Business and International (LB&I) Division of the Internal Revenue Service (IRS) announced its first 13 issue-based campaigns on January 31, 2017. As discussed in a prior Eversheds Sutherland Legal Alert, these...more

N.Y.’s 2018 Budget Proposal: Tax Proposals To Watch

by Farrell Fritz, P.C. on

Last month, Governor Cuomo presented his budget proposal for NY State’s 2017- 2018 fiscal year. Included in the proposal were a number of tax provisions that should be of interest to closely-held businesses and their owners....more

Reporting A Closely Held U.S. Corporation’s Overseas Activities

by Farrell Fritz, P.C. on

We have heard a lot about large, publicly-traded U.S. corporations that have parked trillions of dollars overseas to avoid the payment of U.S. income tax. We have heard how the tax system must be seriously broken to have so...more

Shareholder Liability For Corporate Income Tax?

by Farrell Fritz, P.C. on

Limited Liability - In general, the creditors of a corporation cannot recover the corporation’s debts from its shareholders—the shareholders enjoy the benefit of limited liability protection as a matter of state law....more

IRS Issues New Guidance on TIGER Grants

by Miles & Stockbridge P.C. on

In Revenue Procedure 2017-22, the IRS clarified earlier guidance regarding safe harbors for corporate taxpayers receiving grants from the government for capital improvements to transportation services. Section 118...more

Change is Coming: A Look at Trump and Republican Tax Proposals

by Barley Snyder on

Tax reform is coming, and you better be ready. Regardless of how you voted in November, the United States will have a new president Friday and the Republican Party will be in control of both houses of Congress....more

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