A corporate net operating loss carryover or other tax attribute is valuable because it can be used to offset future taxable income. Congress did not want such attributes to be transferable, so it … more

When a corporation pays personal expenses of its shareholder, the payment is equivalent to a distribution of cash from the corporation to the shareholder. A recent Tax Court Memorandum decision… more

It is well known that sometimes a taxpayer takes a tax position that yields the result it wants even though the result is outside what the tax law allows. Sometimes the IRS does the same, although that tends to be… more

As we continue to absorb the effects of the tax legislation passed in 2017, some taxpayers may want to consider one of the “revenue raisers” contained in that law. That revenue raiser eliminates the… more

Generally, a state has jurisdiction to tax a business only if the business has the required minimum contacts (“nexus”) in the state. Nexus can be established by having personnel or property present in a state, or… more

To elect validly to be taxed as an S corporation (that is, to be free of corporate income tax), a corporation must comply with very specific rules. Failure to comply with the rules means that… more

Tax rules enacted in 2017 allow a 100% bonus depreciation deduction (that is, a full, immediate write-off) not only for certain new property but also for certain used property. That rule can be… more

An S corporation is a “pass-through” entity, meaning it generally does not have to pay corporate income tax. If a corporation has more than one class of stock its election to be taxed as an S corporation is invalid, which means… more

When a business is sold, the seller normally makes promises known as “representations and warranties,” including tax representations and warranties, to the buyer. The buyer is expected to… more

In 2017, Congress passed a new tax bill permitting certain lucky taxpayers a deduction of up to 20% of their “qualified business income.” The Treasury recently finalized regulations providing guidance as to… more

As Spring approaches, our thoughts naturally turn to . . . accounting method changes. This year, the gross income limitation for several beneficial accounting method changes, particularly an expanded option for… more

As the U.S. federal government shutdown nears the end of its first month, taxpayers are discovering that closure of the IRS causes some inconveniences. Some of those inconveniences are only a matter of … more

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