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Archive for Corporate

Tax Court Rules For Amazon Against The IRS

Ron Marini

In 2015, Amazon was bitterly locked in a $1.5 billion transfer pricing dispute with the Internal Revenue Service over an arrangement it inked with a European subsidiary, and the outcome of the case, which is sitting in U.S. Tax Court, is being closely watched by multinationals and tax lawyers alike.

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Garlock: How Not To Structure A Controlled Foreign Corporation

Hale Stewart

A CFC is a foreign corporation where a U.S. shareholder owns “more than” 50% of the offshore company. Practitioners quickly noted the 50% ownership requirement and correctly deduced that, if a non-U.S. shareholder owned the remaining 50%, the foreign corporation could escape being a CFC.

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Income 54: Shareholders of Partnerships and S Corporations

John Dundon

The Colorado Department of Revenue has finally revised its guidelines in FYI Income 54 regarding people who do not live in Colorado but are partners and/or shareholders of partnerships and/or S corporations in Colorado, ensuring that pass-through entities pay Colorado income tax on their Colorado-source income. This Enrolled Agent says “About Time!”

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Canadian FAQ – Shareholders’ Equity – What You Need To Know!

Grant Gilmour

What is Shareholders’ Equity? Shareholders’ Equity is often used to measure the net worth of a company. It is used to assess the financial strength of a company.

Discussion:

Shareholders’ Equity (also commonly referred to as Owners’ Equity) comes from two sources:

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Portland, Oregon Enacts New Surtax For High Executive Pay

Annette Nellen

This week, the City Council in Portland, Oregon modified the business license tax for publicly traded companies subject to SEC reporting. Basically, before the change, this tax is 2.2% of adjusted net income (City Code 7.02.500). The new language increasing this for either a 10% or 24% surtax, follows:

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Set Up Your 2017 Calendar To Reflect New Filing Dates For 2016 U.S. Tax Returns

Ron Marini

On July 31, 2015, President Obama signed into law P.L. 114-41, the “Surface Transportation and Veterans Health Care Choice Improvement Act of 2015,” which includes a number of important tax provisions, including revised due dates for partnership, S corporations and C corporation returns and revised extended due dates for some returns.

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Foreign Asset Reporting For Entities: New For 2016!

Manasa Nadig

There is a lot of attention these days on big companies (Apple, Google, General Electric, Facebook and others) stashing their earnings overseas in what are considered tax havens to avoid paying U.S. taxes on their corporate income. Some international tax reform proposals have been suggested as to how to get the corporation to either bring this stash back into the U.S. by way of a “repatriation holiday” or “deemed repatriation” or ending the system of tax deferrals. Read more

Choosing Between A ‘C’ OR ‘S’ Corporation – Selling Options For your Business

Ron Oddo

Usually, no other factors carry the weight of the tax issue or significantly differentiate the C from the S Corporation. Limited liability is attainable in both the C and S Corporation forms. Voting rights need not differ. An S Corporation conducts business, on a day-to-day basis, exactly as a regular corporation. The only difference between the C and S Corporation is the filing of a one-page IRS form (Form 2553) electing treatment as an S Corporation.

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Choosing Between A ‘C’ OR ‘S’ Corporation – Weighing Tax Attributes

Ron Oddo

Question most CPAs as to what business form they suggest for the business clients and they typically answer, “A C Corporation—at least in the early capital formation years of the business.” Ask any Investment Banker or other Transaction Advisor what entity they prefer and you will likely hear, “An S Corporation or LLC (Limited Liability Company), or perhaps a partnership or sole proprietorship. Anything, anything, but a C Corporation!”

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Important Change: When are Corporate/Partnership Tax Returns Due?

Monika Miles

Do you take notice when it comes to new California tax laws and updates? Here is one that taxpayers and tax preparers alike will want to pay attention to.

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They Could Have Used A Captive Insurance Company: Blue Bell Ice Cream

Blue Bell is often referred to as Texas’ ice cream. It is sold in many restaurants and is prominently displayed in most local grocery stores. Blue Bell has also suffered from several product recalls over the past several years. Last year, they recalled a large amount of product due to a listeria contamination at their Brenham, Texas facility. And now there is news of another recall.

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Good Corporate U.S. Tax Planning Gone Awry?

Ron Marini

A new report released this week by Citizens for Tax Justice (CTJ), the Institute of Taxation and Economic Policy (ITEP) and the US Public Interest Research Group (PIRG) posits that Fortune 500 (US-based) companies have stashed away close to $2.5 trillion in offshore accounts in an effort to reduce their tax burdens.

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