corporate tax attorney minneapolis

Limitations to the Non-Recognition Rules for Asset Transfers to Foreign Corporations

Jan 4th, 2012 | By | Category: corporate tax attorney minneapolis, Legal Notes

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 US taxes? You should be aware that while in certain circumstances it is feasible to transfer such property in order to properly run a business, there are many limitations placed upon [...]

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Tax Effect of a Complete Liquidation of a Corporation on Its Shareholders

Dec 26th, 2011 | By | Category: corporate tax attorney minneapolis, Legal Notes

The tax effects to shareholders of liquidating a corporation are largely governed by IRC Sections 331, 332 (liquidations of subsidiaries) and 338 (dealing with certain stock purchases treated as asset acquisitions). This article will examine only the general tax rule found in Section 331 (keep in mind that there are numerous exceptions and variations depending [...]

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Making the Section 338(g) Election when Purchasing a Target Corporation’s Stock

Dec 19th, 2011 | By | Category: corporate tax attorney minneapolis, Legal Notes

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 certain requirements, to make an election to treat the acquisition as an asset purchase instead of a stock purchase. In the right circumstances, a Section 338(g) election can be a very [...]

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Form 1120S Penalties and Interest

Dec 12th, 2011 | By | Category: corporate tax attorney minneapolis, Legal Notes

Form 1120S (US Income Tax Return for an S Corporation) is used to report the income, gains, losses, deductions, credits, and related items, for any tax year covered, of a domestic corporation or other entity that elects to be treated as an S corporation by filing Form 2553. If the IRS accepts the election, Form [...]

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IRS Form 1120 Schedule UTP Filing Requirements

Nov 14th, 2011 | By | Category: corporate tax attorney minneapolis, Legal Notes

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 stands for “Uncertain Tax Positions”, and the purpose of the schedule is for corporate taxpayers to provide concise disclosure of uncertain tax issues relating to the reporting of reserves in their [...]

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