A subsidiary fails to show that it received the primary benefit from its payment to an adviser incident to a merger.
C Corporation Income Taxation
The IRS issued proposed regulations on the Sec. 162(m) $1 million limit on executive compensation paid by certain publicly held corporations.
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.
In comments submitted to the IRS, the AICPA requested expeditious guidance concerning adjustments attributable to conversions from an S corporation to a C corporation.
Stock-based compensation is held includible in a cost-sharing agreement.
New Jersey's payments to a corporate taxpayer were intended as an inducement to locate in the state.
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.
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.
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.
The regulations define the term “substantially all,” the definition of which was reserved in the earlier proposed regulations issued in October 2018.
The Tax Court also denies capital gain treatment but allows business deductions for a taxpayer's subsequent shooting activity.
Starting this year, C corporations can claim a foreign-derived intangible income deduction of 37.5%.
Advance guidance clarifies that the TCJA's disallowance of deductions for entertainment, amusement, or recreation does not address business meals.
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.
The IRS issued guidance on the deductibility of meal and entertainment expenses after the modification of Sec. 274 by the TCJA.
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.
The order announcing the withdrawal says it is being done “to allow time for the reconstituted panel to confer on this appeal.”
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.
The Ninth Circuit reversed a Tax Court decision invalidating a cost-sharing regulation that requires allocation of stock-based compensation costs between related parties.
The Tax Court holds that the payments were not for rent.