Ideas & Insights

Effective Jan. 1, 2021, the long-standing terminating business gain exclusion for unincorporated business tax purposes is eliminated.

Management fees paid to shareholders not made purely for services and unreasonable in amount are not deductible under section 162.

In line with decades of case law and rulings, IRS ruling looks to benefits and burdens of ownership to determine tax ownership.

Final section 864(c)(8) regulations clarify rules for foreign partners with ECI from transfers of partnership interests.

Misconceptions about the federal research and development tax credit leave many companies paying more tax than required.

Corporate taxpayers filing a consolidated return have an added layer of rules to navigate when carrying back a net operating loss.

As businesses renegotiate debts in the aftermath of COVID-19, it is critical to understand whether the debt is considered publicly traded.

Accelerating worthless stock deductions on an insolvent subsidiary without disposing of the business to increase NOL carrybacks.

The CARES Act provides business and tax relief to portfolio companies and investors. However, affiliation rules could limit SBA loan relief.