Corporation income taxation

S corp. expenses not personally deductible by shareholder as a sole proprietor

A district court denies a taxpayer’s refund claim.
W-2 wages and Sec. 199A

W-2 wages and Sec. 199A

Finding the “sweet spot” to maximize the qualified business income deduction may involve adjusting a business’s workforce.

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.

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.

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.

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.

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.
Understanding the FDII deduction

Understanding the FDII deduction

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

What CPAs need to know about Sec. 199A guidance and SSTBs

One of the areas that accountants are most interested in regarding tax reform is Sec. 199A guidance — and, more specifically, how the deduction for qualified business income relates to a specified service trade or business. Tony Nitti, CPA, addresses some popular questions on that topic.

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.

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.

Income omission triggers 6-year limitation period

Reporting of some S corporation gross receipts is not adequate disclosure of all receipts, the Tax Court holds.
QBI deduction

The new QBI deduction is finally clearer

Proposed regulations issued on Sec. 199A bring welcome guidance.
Meal and entertainment expenses

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.

S corporation shareholder may not revoke tax election

The Tax Court declines to create a precedent and allow an individual S corporation shareholder to unilaterally and retroactively revoke the corporation’s election.

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.

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.”

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.

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.

Levy on husband-and-wife LLC is upheld

Taxpayers’ claim they were a single-member limited liability company is belied by partnership returns, the Tax Court concludes.