Corporate Taxes Internal Revenue Service

News & Analysis as of

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

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

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?

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

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

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

IRS Reduces Built-in Gains Tax Period for REITs to Five Years

One of the key benefits of a real estate investment trust (“REIT”) is that it is effectively a pass through entity for income tax purposes. While a REIT pays tax on its taxable income, it also receives a dividends paid...more

Loans Between Related Entities

What Was Intended? Over the last thirty years, I have reviewed the income tax returns of many closely held corporations and partnerships. Quite often, on Schedule L (the balance sheet), I will see an entry for “other...more

The PFIC Regulations Get a Facelift

On December 28, 2016, the Treasury issued final regulations (T.D. 9806) that primarily address passive foreign investment company (PFIC) ownership and reporting rules and largely adopt 2013 proposed (REG-140974-11) and...more

When Investing In A Partnership May Be A Tax Problem

A business entity that is treated as a “flow-through” for income tax purposes enjoys the benefit of a single level of tax – the entity itself is typically not subject to tax on its net income; rather, that income “flows...more

Focus on Tax Strategies & Developments - December 2016

Significant Changes in US Tax System Likely - In the short time since the surprising election of Donald J. Trump as the 45th president of the United States, much already has been written about the likelihood and likely...more

Defenses Payroll Tax Fraud

Prosecution for payroll tax fraud is a high priority for the IRS and Department of Justice. Payroll tax fraud occurs in several manners, including false worker classification as independent contractors, understatement of...more

Tax Reform Timing - Effective Date of 2018 at the Earliest Based on History

Rumblings in the market suggest that some tax equity investors are preparing for the possibility that the 2017 marginal corporate federal income tax rate may be much lower than the current 35 percent. Such tax equity...more

Where Did All The "S" Corporations Come From?

You just formed your medical practice in Alabama, and you either chose a professional corporation (a "PC") or an LLC. If you went with a PC, you get to choose between an "S" corporation ("S corp") or a "C" corporation ("C...more

What Kind of Tax Changes Can We Expect From Trump's Presidency?

The tears have not yet dried for some, and the celebrating is not yet over for others, but let's turn our attention to taxes. With a Republican Congress and a Republican president, some measure of tax relief is a given. What...more

Renewed Perils from “Zeroing Out” a Corporation at Year-End

Physicians who are involved in the financial management of their practices are all too familiar with the year-end scramble to “zero out” the corporation’s profits. Under this technique, a physician practice that is structured...more

IRS Issues Final and Temporary Debt-Equity Regulations Under Section 385

On October 13, 2016, the Treasury Department and the Internal Revenue Service issued final and temporary regulations under section 385 of the Internal Revenue Code. The final and temporary regulations recharacterize certain...more

"IRS and Treasury Issue Final Debt/Equity Regulations"

On October 13, 2016, the Internal Revenue Service (IRS) and the Treasury Department (Treasury) issued temporary and final Treasury regulations under Section 385 of the Internal Revenue Code of 1986, as amended (the Final...more

U.S. Taxes and the 2016 Election: More of the Same on the International Front

When it comes to proposed tax reform, the devil is always in the details. Business Taxes - On the business tax front, Mr. Trump’s proposal lowers the corporate tax rate to 15% (from a maximum 35%), while Mrs....more

MoFo Tax Talk - Volume 9, No. 3

IRS Issues Proposed Regs on RIC Commodity Investments - On September 27, 2016, the IRS issued proposed regulations (the “Proposed Regulations”) providing guidance relating to the income test and asset diversification...more

Transferee Liability: The [Unlikely] Situation that your Nonprofit Receives a Charitable Gift with Expensive Tax Strings Attached

The case of Salus Mundi Foundation et al v. Commissioner - On August 15, 2016, the Tax Court decided in Salus Mundi Foundation et al v. Commissioner, T.C. Memo. 2016-154, that two foundations were liable as transferees...more

Tax Complications of a $1 Billion Dollar Net Operating Loss

Recently, The New York Times shared information that presidential candidate, Donald Trump, declared a loss of $916 million on his 1995 income tax returns. In response, there has been much speculation that Donald Trump may...more

The Qualified Subchapter S Subsidiary Election – A Primer and Beyond

Mr. Brant’s article offers readers a broad overview of the QSub election and a review of the history surrounding its statutory creation. In addition, it provides a rather in-depth discussion of the QSub qualification...more

IRS to Issue Regulations Addressing Tax Splitter Transactions: Target Is EU State Aid Investigations but Restrictions to Be...

Action prompted by concerns that settlements of EU State Aid tax investigations may result in inappropriate foreign tax credit splitter structures. On September 15, 2016, the US Internal Revenue Service (the IRS) issued...more

Kübler-Ross and IRS Announcement 2016-32

When the IRS announced that it would virtually eliminate the determination letter program for individually designed retirement plans, many practitioners moved through the classic Kübler-Ross five stages of grief. Some have...more

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