Christine Walizer, Author at The S Corporation Association

S-Corp on Section 385

The S Corporation Association has sent a letter to the two congressional tax committees asking them to support efforts to pull Treasury’s proposed section 385 regulations released back on April 4^th. The comment period for these regs doesn’t close until July 7^th, and we intend to submit lengthy comments outlining our numerous concerns with the regulations and how they will hurt Main Street businesses.

But in the meantime, we believe it is important for policymakers to have a better sense of just how far these regulations extend and the costs they will impose on businesses of all stripes operating in …

(Read More)

admin2019-02-01T19:56:24+00:00May 25, 2016|

Senate Finance Hearing on Corporate Integration

Remember the pass-through mantra for tax reform? All business income should be taxed once, it should be taxed at the same top rate, and then we should leave it alone! Well, that mantra was on display Tuesday when a panel of tax experts explored the benefits and costs of corporate integration. Here’s Dr. Michael Graetz:

“In the 1990s, principally because of its administrative advantages, the Treasury Department recommended taxing business income once—at the business level. This form of integration was advanced by President George W. Bush in 2003, but Congress instead simply lowered shareholders’ income tax rates on dividends. That …

(Read More)

admin2019-02-01T19:56:24+00:00May 19, 2016|

Reichert, Buchanan Present S Corp Tax Relief to Ways and Means

As our members know, S-Corp wears two hats when it comes to advocacy – one is defensive where we protect S corporations from bad tax policy. The other is proactive and seeks to improve the S corp rules.

Both hats were on display this week before the House Ways & Means Committee. First, Rep. Dave Reichert (R-WA) discussed his S Corporation Modernization Act which makes a number of improvements to the S corporation rules, including opening the door to foreign investment into S corporations. As Rep. Reichert told the Committee:

Click on …

(Read More)

admin2019-02-01T19:56:24+00:00May 13, 2016|

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 …

(Read More)

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 …

(Read More)

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