Shareholders, Tax Returns, S-Corporation

A Journey Through Subchapter S / A Review of The Not So Obvious & The Many Traps That Exist For The Unwary: Part XVI – Changes in...

Foster Garvey PC on 4/4/2025

Now that the scurrying around and worrying relative to developments impacting the Corporate Transparency Act (“CTA”) that were coming at us with laser speed are on a slow simmer, I can turn my attention back to my multi-part...more

A Journey Through Subchapter S / A Review of The Not So Obvious & The Many Traps That Exist For The Unwary: Part XIII – What...

Foster Garvey PC on 11/14/2024

Basic Rules - IRC § 6501(a) generally requires the IRS to assess tax within three (3) years after a tax return is filed by the taxpayer. There are two (2) notable exceptions to this rule under IRC § 6501(c) and (e),...more

When A Shareholder Loses Control of Their S Corporation

Rivkin Radler LLP on 8/20/2024

If given their druthers, most transactional corporate attorneys would prefer to spend their day practicing “happy law,” by which they typically mean transactions that involve capital formation, mergers and acquisitions, joint...more

New York Appellate Court Rules in Favor of S Corporation Shareholder Entitlement to New York QEZE Tax Credits

Blank Rome LLP on 1/19/2024

In a pair of decisions, a New York State appellate court has annulled decisions of the New York State Tax Appeals Tribunal that reduced certain tax credits available to the individual shareholders of their S corporation....more

IRS Provides Much Needed Transition Relief for New Schedules K-2 and K-3

Butler Snow LLP on 2/18/2022

February 18, 2022 On February 16, 2022, the IRS issued a news release along with a set of “Frequently Asked Questions” on new Schedules K-2 and K-3, which must be filed with IRS Forms 1065, 1120-S and 8865. This guidance was...more

Tax Changes In The Offing? “Close Scrutiny” Of Business Owners’ Economic Benefits Remains A Constant

Rivkin Radler LLP on 6/21/2021

I Read the News Today- Much of today’s news is dominated by the future of the Administration’s broadly defined infrastructure plan. Discussions among “those in the know” inevitably turn into debates over the wisdom of...more

It’s Not Too Late!—Untimely S Elections

Freeman Law on 12/8/2020

In my practice, I have seen various issues related to a taxpayer’s S election. Corporations potentially jeopardize their S election by unknowingly creating a second class of stock through convertible debt. Corporations,...more

More Related Party Transfers

Farrell Fritz, P.C. on 8/14/2018

Last week, we considered the proper tax treatment for a transfer of funds from a parent corporation to its foreign subsidiary. The parent had argued, unsuccessfully, that the transfer represented the payment of a deductible...more

Shareholder Oppression, S Corps, & A Second Class Of Stock?

Farrell Fritz, P.C. on 7/16/2018

Woe to the Oppressed Shareholder- As I write this post on Bastille Day, I am reminded how an oppressed people, realizing the injustice of their circumstances, and having reached the limits of their endurance, took the first...more

Choice Of Entity, Shareholder Disputes, And The Discovery Of Tax Returns

Farrell Fritz, P.C. on 7/2/2018

The reduction in the Federal income tax rate for C corporations, from a maximum of 35-percent to a flat 21-percent, along with several other changes made by the Tax Cuts and Jobs Act (the “Act”) that generally reflect a pro-C...more

S Corp. Shareholder To Tax Court: “Here’s Why I Deserve These Loss Deductions”

Farrell Fritz, P.C. on 11/20/2017

A post earlier this year considered the basis-limitation that restricts the ability of S corporation shareholders to deduct their pro rata share of the corporation’s losses. It was observed that, over the years, shareholders...more

Related-Party Provisions Prevent Deduction by S Corp Shareholders - Tax Update Volume 2017, Issue 4

Troutman Pepper Locke on 7/27/2017

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

IRS Issues Proposed Rules on Income Inclusion under Section 50(d)(5)

Foley & Lardner LLP on 7/29/2016

The IRS just published long-awaited temporary regulations under section 1.50-1T governing the section 50(d)(5) income inclusion rules. These rules apply to lessees of investment credit property when the lessor elects to treat...more

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