Corporation income taxation

TOPICS / TAX

January 1, 2020

No deduction for paying corporate parent’s expense

A subsidiary fails to show that it received the primary benefit from its payment to an adviser incident to a merger.

December 17, 2019

Proposed regs. would govern Sec. 162(m) executive compensation limits

The IRS issued proposed regulations on the Sec. 162(m) $1 million limit on executive compensation paid by certain publicly held corporations.

December 1, 2019

Business tax quick guide — tax year 2019

Download and print this quick guide for use during tax season, and look for our quick guide for individual taxpayers in the January 2020 issue.

September 26, 2019

AICPA seeks guidance on adjustments for conversions from S corp. to C corp.

In comments submitted to the IRS, the AICPA requested expeditious guidance concerning adjustments attributable to conversions from an S corporation to a C corporation.

September 1, 2019

Ninth Circuit overturns Tax Court’s invalidation of transfer-pricing regs.

Stock-based compensation is held includible in a cost-sharing agreement.

August 1, 2019

State cash grants were nontaxable contributions to capital

New Jersey’s payments to a corporate taxpayer were intended as an inducement to locate in the state.

June 18, 2019

W-2 methods proposed for Sec. 199A(g) deduction by agricultural co-ops

The IRS issued methods for calculating W-2 wages for the Sec. 199A(g) deduction for agricultural and horticultural cooperatives, similar to the former Sec. 199 domestic production activities deduction.

June 10, 2019

Ninth Circuit upholds IRS cost-sharing regulation

The Ninth Circuit Court of Appeals reversed a Tax Court decision that had held that a cost-sharing regulation that required allocation of stock-based compensation was invalid.

May 10, 2019

Distribution by former S corporation is part dividend

The IRS ruled that a distribution to the sole shareholder of a C corporation was partly a recovery of the former S corporation’s accumulated adjustments account (AAA) and a taxable dividend for the remaining distribution.

April 17, 2019

More proposed regs. on qualified opportunity funds issued

The regulations define the term “substantially all,” the definition of which was reserved in the earlier proposed regulations issued in October 2018.

March 1, 2019

Salesman’s termination payment held not for goodwill

The Tax Court also denies capital gain treatment but allows business deductions for a taxpayer’s subsequent shooting activity.

February 1, 2019

Understanding the FDII deduction

Starting this year, C corporations can claim a foreign-derived intangible income deduction of 37.5%.

January 1, 2019

Meals continue to be deductible under IRS guidance

Advance guidance clarifies that the TCJA’s disallowance of deductions for entertainment, amusement, or recreation does not address business meals.

November 27, 2018

Proposed regs. outline new business interest expense limitation

The IRS issued proposed regulations on the business interest expense limitation in Sec. 163(j), which was amended by the law known as the Tax Cuts and Jobs Act.

October 3, 2018

Meals continue to be deductible under new IRS guidance

The IRS issued guidance on the deductibility of meal and entertainment expenses after the modification of Sec. 274 by the TCJA.

August 22, 2018

IRS provides initial guidance on new Sec. 162(m)

The IRS issued guidance regarding amended Sec. 162(m), which limits the allowable deduction for remuneration paid by any publicly held corporation to a covered employee to $1 million.

August 7, 2018

Ninth Circuit withdraws Altera opinion

The order announcing the withdrawal says it is being done “to allow time for the reconstituted panel to confer on this appeal.”

August 1, 2018

Proposed regs. address several transition tax issues

The IRS issued proposed regulations on the Sec. 965 transition tax that requires U.S. shareholders of deferred foreign income corporations to pay tax on post-1986 deferred income.

July 25, 2018

Stock-based compensation cost-sharing regs. valid

The Ninth Circuit reversed a Tax Court decision invalidating a cost-sharing regulation that requires allocation of stock-based compensation costs between related parties.

May 1, 2018