Corporate Taxes, Internal Revenue Code (IRC), Private Letter Rulings

Accidental Termination on Purpose? S Corp Ruling Could Be Huge For QSBS Owners

DarrowEverett LLP on 4/3/2024

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

Two New Private Letter Rulings Inform Code Section 1202's Qualified Trade or Business Analysis

Keating Muething & Klekamp PLL on 2/21/2022

Section 1202 of the Internal Revenue Code provides savvy business founders and investors an opportunity for large tax savings. In fact, if the entity and the business exit are structured correctly, upon an exit, the founders...more

Mere Change?—“F” Reorganization Qualifies in Spite of Change in Plan

Freeman Law on 1/29/2021

Former British Prime Minister Winston Churchill once said, “Plans are of little importance, but planning is essential.” Perhaps that quote is a tad strong to apply generally to corporate reorganizations under Section 368 of...more

S Election Terminated as a Result of Form Operating Agreement Language

Mitchell, Williams, Selig, Gates & Woodyard,... on 5/7/2019

A limited liability company (an “LLC”) is a business structure created by state statute, but it is not a distinct business entity for tax purposes (like a partnership or a corporation). Instead, businesses structured as LLCs...more

Weekly IRS Roundup February 11 – 15, 2019

McDermott Will & Emery on 2/20/2019

Presented below is our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of February 11 – 15, 2019. February 11, 2019: The IRS issued a news release promoting online...more

Recent U.S. Tax Developments Affecting Publicly Traded Partnerships

Dechert LLP on 3/13/2015

Partnerships targeted to widespread investors are a popular investment vehicle and a significant source of funding for oil and gas projects. However, their use is affected by the publicly traded partnership (“PTP”) tax rules....more