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Appeals Court Limits Application Of Substance-Over-Form Doctrine
The Sixth Circuit reversed the Tax Court and held that the IRS could not apply the substance-over-form doctrine to recharacterize commission payments made to a domestic international sales corporation (DISC) that was owned by a Roth IRA.
United States
27 Mar 2017
Tax Court Holds That Co-Borrowing Does Not Generate S Corp Debt Basis
The U.S. Tax Court held that a shareholder of several S corporations did not receive any basis in indebtedness to the S corporations merely from signing as a co-borrower on loans....
United States
26 Jan 2017
Treasury Issues Proposed Regulations On Deemed Distributions Of Stock
Treasury and the IRS issued proposed regulations (REG-133673-15) related to distributions of a corporation's stock under Section 305.
United States
5 May 2016
S Corporation Cannot Take An Ordinary Worthless Stock Deduction
In general, Section 165(g)(1) provides for the recognition of a capital loss for any security that is a capital asset that becomes worthless.
United States
5 Feb 2016
IRS Rules On Implications For The Active Trade Or Business Requirements Of Section 355
The IRS recently ruled in a private letter ruling (PLR 201551009) on the implications of gain recognition under Section 751 in the context of a Section 355 spinoff.
United States
5 Feb 2016
IRS Rules On The Continuation Of A Consolidated Group
The IRS has ruled (PLR 2015-05-006) that the parent of a consolidated group had three classes of stock outstanding.
United States
12 Feb 2015
IRS Rules On Determining Voting Power Related To Section 355
The IRS has ruled in PLR 2015-05-007 that the voting power of stock within the meaning of Section 355(d) was determined by reference to the ability to elect members of the corporation’s board of directors.
United States
12 Feb 2015
Shareholders Allowed To Increase Tax Basis In Their S Corporation Stock For Certain Tax-Exempt Awards
The IRS allowed individual shareholders of an S corporation to increase their basis in the stock of the S corporation.
United States
20 Oct 2014
Tax Court Holds That Certain Shareholders Received A Gift In A Merger Of Two Corporations
Certain shareholders received a gift from other shareholders, to the extent that the value of the shares of stock received in a merger exceeded the value of the shares of stock transferred.
United States
13 Oct 2014
Final Regulations On Back-To-Back Loan By S Corporation Shareholders Issued
The IRS issued final regulations (T.D. 9682) relating to when S corporation shareholders have basis in indebtedness that the S corporation owes to them.
United States
27 Aug 2014
IRS Memo Describes Effect Of Disallowed Section 311(A) Loss On S Corporation, Shareholders
The IRS ruled that a loss disallowed under Section 311(a) reduced a shareholder’s basis in S corporation stock.
United States
16 Jun 2014
IRS Issues Notice On Treatment Of U.S. Shareholders Owning PFIC Stock Through Taxexempt Organizations Or Accounts
The IRS intends to amend regulations to provide guidance concerning the treatment of U.S. persons that own stock of a passive foreign investment company.
United States
29 Apr 2014
IRS Rules Distribution Agreement Does Not Create Second Class Of Stock
The IRS has ruled in PLR 2013-06-004 that an S corporation's distribution agreement with its shareholders would not create a second class of stock under Section 1361(b)(1)(D).
United States
8 Mar 2013
On the Horizon - January 15, 2013
Special dividends may impact on the accounting for share-based compensation.
United States
22 Jan 2013
Taxpayers Had Income From Cancellation Of Split-Dollar Life Insurance Policy
In Neff v. Commissioner, T.C. Memo 2012-244 (8/27/12), the Tax Court addressed the tax consequences of the rollout of a split-dollar life insurance policy under guidance issued by the IRS under prefinal split-dollar regulations (T.D. 9092, 68 Fed. Reg. 54336 (9/17/03)) regarding the proper treatment of such policies applicable to split-dollar life insurance arrangements (SDLIAs) entered into after Sept. 17, 2003.
United States
17 Sep 2012
11th Circuit Affirms Purported Loan Constituted A Sale
The 11th Circuit Court in Lizzie W. Calloway et vir v. Commissioner (No. 11-103965 (11th Cir., (2012)) affirmed the Tax Court’s decision (135 T.C. 3 (2010) that a taxpayer sold his stock upon entering into an agreement that purported to be a nonrecourse loan.
United States
17 Sep 2012
IRS Proposes Regulations Under Section 83
The IRS recently proposed regulations (REG-141075-09) under Section 83 to clarify and make changes to the current regulations.
United States
25 Jun 2012
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