Corporation income taxation
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.Ninth Circuit overturns Tax Court’s invalidation of transfer-pricing regs.
Stock-based compensation is held includible in a cost-sharing agreement.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.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
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
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.
The new QBI deduction is finally clearer
Proposed regulations issued on Sec. 199A bring welcome guidance.
