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Foster Garvey PC

A Journey Through Subchapter S / A Review of The Not So Obvious & The Many Traps That Exist For The Unwary: Part XVI – Changes in...

Foster Garvey PC on

Now that the scurrying around and worrying relative to developments impacting the Corporate Transparency Act (“CTA”) that were coming at us with laser speed are on a slow simmer, I can turn my attention back to my multi-part...more

Lippes Mathias LLP

Taxpayer Beware: The Pitfalls of Section 965 Installment Payments

Lippes Mathias LLP on

For the taxable years ending on December 31, 2017, and 2018, Section 965[1] of the Internal Revenue Code required U.S. shareholders (as defined in Section 951(b)) to pay a transition tax on the untaxed foreign earnings of...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 XIII – What...

Foster Garvey PC on

Basic Rules - IRC § 6501(a) generally requires the IRS to assess tax within three (3) years after a tax return is filed by the taxpayer. There are two (2) notable exceptions to this rule under IRC § 6501(c) and (e),...more

Ward and Smith, P.A.

Tax Treatment of the Sale of Social Club Assets Upon Liquidation

Ward and Smith, P.A. on

Since 1916, Congress has exempted from income taxation clubs formed to facilitate social interaction between its members.  As a result, country clubs, hunting and fishing clubs, college sororities and fraternities, and...more

Foodman CPAs & Advisors

IRS “BEEFS UP” Section 965 COMPLIANCE For 2017 And 2018 Returns

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On July 2, 2018, the IRS introduced a Compliance Campaign directed at Section 965 (Transition Tax) of the Internal Revenue Code (IRC). In its original launch, the Section 965 Campaign stated that U.S. shareholder are...more

Farrell Fritz, P.C.

The Closely Held Business & The Minority Owner: Accessing Information From The Entity’s Tax Return?

Farrell Fritz, P.C. on

Why a Minority Owner? I have often asked the question, “Why would someone willingly become a minority owner in a closely held business?” Similarly, I have often advised clients who control their own business not to admit a...more

Troutman Pepper Locke

Related-Party Provisions Prevent Deduction by S Corp Shareholders - Tax Update Volume 2017, Issue 4

Troutman Pepper Locke on

Many routine transactions occur between related parties, including the payment or accrual of interest on indebtedness, license fees, salary or benefits to employees and/or shareholders, and trade invoices. The Tax Court...more

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