The final regulations under Section 1374: built-in issues and opportunities

Article Abstract:

IRC section 1374 final regulations concern the built-in gains tax on S corporations that apply to converted C corporations that elected S status after 1986. The regs describe a four-step tax computation where net recognized built-in gain is determined and then reduced by allowable capital loss carryforwards and net operating losses, producing a tentative tax reducible by allowable credits. The regs cover special applications such as accrual and deduction items, inventories, installment sales, completed contract accounting, discharge of debt income or expenses for bad debts, and s. 481 adjustments. Partnership interest guidance is also provided in the regs.

S corporations

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IRS issues new regs. on basis adjustments to intangibles, but confusion still reigns

Article Abstract:

The author discusses IRS regulations adjusting basis for intangible assets arising from valuation changes, resulting from technological changes developed in multi-firm alliances.

Economic aspects, Valuation, Intangible property, Intangible assets, Strategic alliances (Business), Basis (Taxation)

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Final regulations issued for applying look-through rules to sales of pass-through entities for purposes of classifying capital gains

Article Abstract:

The author discusses final regulations regarding capital gains classification for pass-through entities sales and argues they leave several issues unanswered.

Transfer (Law)

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