1. TAX

Corporation income taxation

New corporate anti-inversion rules issued

the IRS announced additional rules designed to curtail the ability of an inverted company to access foreign subsidiaries’ earnings without paying U.S. tax.

Substance-over-form doctrine used to nix growth within Roth IRAs

Purported DISC commissions paid to Roth IRAs as owners of a holding company are recharacterized as dividends to shareholders and excess contributions.

Tax Court to reconsider its previous denial of stockholders’ transferee liability

Ninth Circuit remands a case for analysis of a stock sale’s economic substance.

Tax Court invalidates stock-based compensation rule in cost-sharing agreements

The Tax Court held that Regs. Sec. 1.482-7(d)(2), requiring entities to share stock-based compensation costs under qualified cost-sharing agreements, failed to meet the reasoned decision-making standard and was invalid.

Helping S corporations avoid unreasonable compensation audits

The IRS aggressively audits S corporations to make sure they do not disguise compensation as distributions to shareholders. Here’s what tax preparers need to know to avoid red flags in S corporation returns.

Tax practice responsibilities involved in Schedule UTP

The need to file Schedule UTP, Uncertain Tax Position Statement, may have taken many corporate taxpayers by surprise in 2014, since the asset threshold for compliance was lowered from $50 million to $10 million.

Sec. 4980D excise tax relief is available for certain small employers

IRS gives limited transition relief for employer payment plans and 2% S corporation shareholder arrangements.

FASB proposes two changes to simplify accounting for income taxes

FASB proposed two standards changes that are designed to reduce complexity in accounting for income taxes.

Merged corporations can offset tax interest

The surviving corporation and acquired corporations in a merger are considered the same taxpayer for purposes of interest offsetting.

Regulations tightening Form 5472 filing requirements are finalized

The IRS finalized proposed regulations issued last June requiring corporations to file Form 5472 with their timely filed tax returns or pay a large penalty.

IRS puts would-be corporate inverters on notice

Coming regulations will reduce tax benefits of inversions by preventing certain uses of controlled foreign corporations and closing loopholes in the Sec. 7874 anti-inversion provisions.
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