Many routine transactions occur between related parties, including the payment or accrual of interest on indebtedness, license fees, salary or benefits to employees and/or shareholders, and trade invoices. The Tax Court...more
7/27/2017
/ Employee Benefits ,
ESOP ,
Income Taxes ,
Internal Revenue Code (IRC) ,
IRS ,
Payroll Records ,
Related Parties ,
S-Corporation ,
Shareholders ,
Tax Deductions ,
Tax Returns
The active trade or business rules are detailed and highly fact specific, and the IRS continues to refine its view on the qualification requirements.
In order to separate two businesses housed in one corporation or in a...more
The recent guidance under section 355 is a significant attempt by the IRS to clarify in a formal way what it historically has been able to do on a case-by-case basis through the private letter ruling process....more