Christine Walizer, Author at The S Corporation Association

Treasury’s Section 385 Regs and S Corps

The business community is beginning to recognize that Treasury’s new Section 385 regulations published on April 4^th have a much broader reach than anybody thought. S corporations in particular need to pay attention.

How broad are they? Here’s how Tax Notes described a meeting of the ABA Section of Taxation here in DC last week:

Practitioners who specialize in the taxation of S corporations said they’re concerned that many S corps may end up gratuitously losing their S corp status if the new related-party debt rules are applied as written without exception.

Thomas J. Nichols of Meissner Tierney Fisher & Nichols SC said that …

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admin2019-02-01T19:56:24+00:00May 11, 2016|

Rate Parity Bill Introduced!

For five years, the S Corporation Association and its allies have asked tax writers to pursue business tax reform that taxes all business income just once and at the same, reasonable top rates. That’s the correct way to tax business income and more than 100 trade groups, including the largest trade groups in the country representing millions of employers, have signed on to this premise.

And for five years, we’ve watched as the tax code moved in exactly the opposite direction.

Instead of preserving rate parity, the combination of the Fiscal Cliff and the implementation of the Affordable Care Act resulted in …

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admin2019-02-01T19:56:25+00:00April 29, 2016|

More on Corporate Integration

Lots of chatter on corporate tax reform last week. First, Finance Committee Chair Orrin Hatch gave a speech on the Senate floor making clear that only comprehensive changes to our tax code would help to make our tax treatment of business income more internationally competitive and end the ongoing exodus of US companies to foreign tax jurisdictions.

Well, at the same time, most of the proposals we’ve seen to deal with inversions would amount to building a virtual wall – a wall forged in regulation and punitive tax treatment – around the country to keep companies from leaving and making …

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admin2019-02-01T19:56:25+00:00April 25, 2016|

Administration Updates its Corporate Tax Reform Proposal

Lost in all the hoopla over the Treasury’s new inversion policies was the accompanying update to their corporate tax reform outline. You can read the whole 30-page document here, but the bottom line is that not much has changed.

The plan still treats the pass-through community as second-class citizens by broadening the tax base for all businesses while only reducing rates for those organized as C corporations. As a result, successful pass-through businesses would be subject to 45 percent top rates on a broader base of income – a double whammy coming just three years after the Fiscal Cliff hiked …

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admin2019-02-01T19:56:25+00:00April 7, 2016|

New Name, Same Mission

It’s a new year, so we’ve rolled out the latest version of our pass-through business principles. As in previous years, the letter hits on the three key elements necessary for any successful tax reform plan – it needs to be comprehensive, restore rate parity, and continue to reduce or eliminate the double tax on corporate income.

Also as in previous years, the list of signatories is long! With more than 100 national business groups signed on, the letter once again demonstrates the widespread support for tax reform that treats Main Street employers as equal partners.

What is new this year, however, is …

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admin2019-02-01T19:56:25+00:00March 22, 2016|