Control of a Set-aside Entity
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
The final regulations adopt the provisions of the previously proposed regulations with modest modifications and clarifications. The registration portal for transferring tax credits is open, and no significant changes have...more
Several abusive tax shelters in the 1970s and 1980s caused Congress to enact rules to prevent taxpayers from deducting losses when a taxpayer doesn’t materially participate in the activity. These passive loss rules apply to...more
Widely held partnerships are a significant source of funding for oil, gas and certain natural resources projects, but the publicly traded partnership (“PTP”) rules can cause such partnerships to be treated as corporations for...more
In April 24’s Federal Register, the IRS released proposed regulations (REG-108214-15) to restrict when a foreign insurance company’s income can be excluded as passive income by giving a more strict definition for the “active...more
Summary - The Small Business Administration (SBA) adopted revisions to its regulations, loosening its prohibition on small business investment companies (SBICs) investing in passive businesses. Under the revised...more