Subpart F in turmoil: low-taxed active income under siege

Article Abstract:

The IRS lacks authority for its hybrid business entity and contract manufacturing regulations which are aimed at reducing legitimate foreign tax credits on active income. The IRS has extended IRC Subpart F rules applicable to controlled foreign corporation passive income beyond their intended application and to the detriment of US multinational businesses.

International, Contract manufacturing, Foreign tax credit, Controlled foreign corporations, Passive activity (Taxation)

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Are some punitive damage awards still excludible from income? Tax Court provides guidance in N.O. Whitley

Article Abstract:

The author discusses the Tax Court case N.O. Whitley where the court described the specific factors which would control the taxation of punitive damage awards under IRC section 104, pursuant to the U.S. Supreme Court holding in K.M. O'Gilvie.

Exemplary damages, Punitive damages, Tax exclusion

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The effect of cancellation of indebtedness income on S corporations after Gitlitz

Article Abstract:

The author discusses the impact of the US Supreme Court's decision in Gitlitz on S corporation cancellation of indebtedness income taxation.

Extinguishment of debts, Debt cancellation, Corporate income taxes, S corporations

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