inversions - The S Corporation Association

More on 385

S-Corp continues its efforts to educate policymakers about the pending Section 385 rules and the harm they will cause to domestic employers and American jobs starting…well, now.

That’s the dirty little secret about the 385 rules. Released as part of a package of “anti-inversion and base erosion” tools, much of their impact will be on normal domestic business practices instead. All that is necessary to be subject to the rule is 1) a group of investors that controls two or more corporations and 2) a loan or cash pooling between members of the group.

That’s it. No international component required. And the …

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admin2019-02-01T19:56:24+00:00June 23, 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 …

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

Extenders – The Post-Thanksgiving Update

Lots of noise on the extender front, but is there progress being made? Hard to tell. Last week, a list of potential items made the rounds that would have made some provisions permanent, some extended for 5 years, and some extended for 2 years. Specifically, the list included:

Permanent: All the House passed permanent provisions, including small business expensing and the shorter built-in gains recognition period but not bonus depreciation, plus changes to the American Opportunity tax credit, child tax credit, the earned income tax credit.
5-Year: Bonus depreciation, the Production Tax Credit and Investment Tax Credit, and the Work Opportunity Tax …

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admin2019-02-01T19:59:03+00:00December 2, 2015|

S Corporation News Clips | December 15-23, 2014

A compilation of the tax-related stories that caught our eye:

Business Tax Reform

The White House is planning on meeting with Republican lawmakers in the days leading up to the State of the Union to push their tax reform plan, pledging to “make sure that we put forward some pretty specific proposals…” Tax reform came up during the President’s year-end press conference as well, part of his ongoing message that he “wants a serious attempt at tax reform next year.”

Combine those comments with noise from the Hill and downtown and there seems to be a critical mass of interest …

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admin2019-02-01T20:00:30+00:00December 23, 2014|

S-CORP Clips | Week of December 12

A compilation of the business tax related stories that caught our eye

Hatch Tax Reform Report

For weeks, there had been K Street rumors of a “secret” tax reform plan being put together by in-coming Finance Committee Chairman Orrin Hatch (R-UT). Apparently, the “Comprehensive Tax Reform for 2015 and Beyond” report released yesterday is it, although it’s not so much a plan as an analysis of the current code and the challenges policymakers will face in reforming it. After a quick review, it’s obvious the Finance Republican staff spent an enormous amount of time and effort putting this together and it …

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admin2014-12-12T16:22:29+00:00December 12, 2014|