No. 55-11, November 2024
Index
- Basis-shifting transactions involving partnerships and related parties.
- Choice-of-entity analysis with the TCJA sunset approaching. (Tax Cuts and Jobs Act of 2017)
- Cleaning up intercompany debt: An intercompany loan between related corporations may be recharacterized as an equity contribution by the companies' shareholders, resulting in a constructive dividend to the shareholders. This article focuses on a recent Tax Court case involving the proper characterization of purported intercompany loans between two S corporations. (Estate of Fry v. Commissioner)
- Client advisory service for business owners. (FEATUREADVERTISING SUPPLEMENT)
- Conflicts of interest in tax practice.
- Connelly clarifies estate treatment of stock redemption.
- Consolidated return filing for subsidiary in receivership.
- FBAR penalties can violate Excessive Fines Clause. (foreign bank account reporting)
- Implications of the Supreme Court's Moore decision.
- IRS makes progress on backlogged ERC claims. (employee retention credit)
- Lawsuit proceeds includible in income. (Estate of Finnegan v. Commissioner)
- LLC validly elected into BBA partnership examination regime. (Bipartisan Budget Act of 2018) (SN Worthington Holdings L.L.C. v. Commissioner) (limited liability companies)
- Overlapping expenses affect multiple tax credit calculations.
- Sec. 245A dividends-received deduction allowed for Sec. 78 dividend.
- Tax strategies for cash and cash equivalents.
- The CHIPS Act's advantageous direct-pay election. (Creating Helpful Incentives to Produce Semiconductors and Science Act of 2022)
- Valuing conservation easements for charitable contributions. (Excelsior Aggregates L.L.C. v. Commissioner)