Limitations to the Non-Recognition Rules for Asset Transfers to Foreign Corporations
Are you thinking of transferring appreciated property to a foreign corporation in order to utilize the corporate “non-recognition” rules, and to possibly avoid further [...]
Tax Effect of a Complete Liquidation of a Corporation on Its Shareholders
The tax effects to shareholders of liquidating a corporation are largely governed by IRC Sections 331, 332 (liquidations of subsidiaries) and 338 (dealing with [...]
Making the Section 338(g) Election when Purchasing a Target Corporation’s Stock
This article will explain Internal Revenue Code Section 338(g), which allows corporations, that buy a certain percentage of a target corporation’s stock and meet [...]
Form 1120S Penalties and Interest
Form 1120S (US Income Tax Return for an S Corporation) is used to report the income, gains, losses, deductions, credits, and related items, for [...]
IRS Form 1120 Schedule UTP Filing Requirements
The IRS recently announced that Schedule UTP must be filed with Forms 1120, 1120-F, 1120-L or 1120-PC, if an entity meets certain requirements. UTP [...]