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2. American Bar Association Section of Taxation Comments on Draft Revenue Procedure Addressing Issues Under Section 1362(f)

Author

Kugler, Paul R.

Subjects
Tax elections -- Laws, regulations and rules, S corporations -- Taxation, Government regulation, Law, Internal Revenue Code I.R.C. 1362(f)
Abstract

I. Introduction (1) For many corporations and shareholders, an election to be treated as an S corporation is a valuable tax-planning tool, as it allows the income of the corporation [...]

Published
2018

9. Vainisi: Seventh Circuit reverses Tax Court in QSub bank decision.

Author

Harris, Deanna Walton, Kugler, Paul F., and Mandreda, Richard H.

Subjects
Interest deductions -- Laws, regulations and rules, S corporations -- Taxation, Banking industry -- Taxation, Subsidiary corporations -- Taxation, Vainisi v. Commissioner (No. 09-3314 (7th Cir. Mar. 17, 2010)), Banking industry, Government regulation, Internal Revenue Code (I.R.C. 291(a)(3))
Published
2010

10. IRS succeeds with an unexpected argument regarding a QSub bank.

Author

Harris, Deanna Walton, Kugler, Paul F., and Mandreda, Richard H.

Subjects
S corporations -- Taxation, Subsidiary corporations -- Taxation, Banking industry -- Taxation, Corporate income taxes -- Laws, regulations and rules, Vainisi v. Commissioner (132 T.C. No. 1 (2009)), Banking industry, Government regulation, Internal Revenue Code (I.R.C. 1363(b)(4)), Internal Revenue Code (I.R.C. 581)
Published
2009

13. Recent amendment to sec. 1374 provides limited opportunity for S corps.

Author

Harris, Deanna Walton and Kugler, Paul

Subjects
Recognition of gain or loss (Taxation) -- Laws, regulations and rules, S corporations -- Taxation -- Laws, regulations and rules, Corporate income taxes -- Laws, regulations and rules, Government regulation, American Recovery and Reinvestment Act of 2009, Internal Revenue Code (I.R.C. 1374)
Abstract

On February 17, 2009, the American Recovery and Reinvestment Act of 2009, P.L. 111-5 (ARRA), was enacted. ARRA contains numerous tax breaks for individual and corporate taxpayers. Of particular relevance [...]

Published
2009

26. Revenue Procedure Attempts to Clarify Entity Classification Election.

Author

Kugler, Paul and Harris, Deanna Walton

Subjects
TAXATION of business enterprises, DISREGARDED entities (Taxation), BUSINESS partnerships, TAXATION
Abstract

The article reports that certain entities can elect passthrough tax treatment for U.S. federal tax purposes by simply checking the box indicating whether the taxpayer is a disregarded entity or a partnership. Recommendations are made for those faced with uncertainty in making an election for passthrough treatment, including what to do if a taxpayer has determined it has checked the wrong box. The Revised Procedure 2010-32 is cited as a well-intentioned but limited attempt to provide an efficient mechanism to ensure an entity's correct classification.

Published
2011

28. Lawyers, insurance agents work together on business solutions.

Author

James, Nancy and Kugler, Paul

Abstract

Offers differing perspectives from lawyers and insurance agents on issues concerning a business' liability exposure. Effect of incorporation on insurance coverage; Limiting liabilities under contract; Need for purchasing insurance when incorporating.

Published
1997

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