* A corporation
that leaves a consolidated group before the end of the short period effecting a change in tax year by the consolidated parent cannot obtain automatic consent to change its tax year using Rev.
An S corp's taxable income flows directly through to its shareholders, increasing their tax bases in the corporation
This case raises important and fundamental questions in respect of the Large Corporation
rules that warrant resolution by this Court.
The general rule is that following a valid S election, shareholders must report and pay tax on the corporation
As it has evolved over the last 150 years, the American corporation
is more than just a mode of business.
The proposals would repeal the S corporation
rule for C corporations
that have a value of $5 million or more at the time of conversion (or at the time of a merger into an existing S corporation
), and subject such conversions to immediate tax on the built-in gains.
Executives admit that suppliers often get contracts because someone in the corporation
knows and likes them.
Following the TIPRA amendment, for distributions made after May 17, 2006 and before 2011, all members of a corporation
's separate affiliated group are treated as one corporation
for purposes of the active-conduct test.
Because the initial response to an SEC investigation is crucial, a corporation
that receives an SEC voluntary information request or a subpoena should immediately attempt to determine the following:
1.367(b)-3(b)(3) requires an exchanging shareholder that is a United States Shareholder of the foreign acquired corporation
to include in income as a deemed dividend the all earnings and profits amount with respect to its stock in the foreign acquired corporation
In 1983, Charlie Johnson was hunting for ways to keep his Bering Straits Corporation
a step ahead of the wolves when he ran into Patrick Beattie, an accountant for the Anchorage office of Peat Marwick Mitchell & Co.
* THE CRITICAL ISSUE FOR TAX PLANNING is whether the assets distributed are considered property under IRC code section 336 and whether the corporation
is an artifice of government, no less than the welfare system or foreign aid.
But, Brooks said, how the departments will be staffed varies from one corporation
to another depending on their needs.
The new temporary and proposed regulations address the exception for "substantial business activities" in the foreign country, for purposes of determining whether the foreign entity is treated as a surrogate foreign corporation
. under Sec.