Tax planning pays for the S corporation buyer and seller
Article Abstract:
S corporations have continued to be a primary form of business organization for closely held firms since their creation in 1958. S firms offer entrepreneurs a way of circumventing the double tax charge required by the C corporation form. Many S firms become attractive acquisition targets and S corporation mergers have led to a host of tax problems accompanying their acquisition or sale. Tax practitioners need to understand the dynamics of these tax issues to negotiate and close a workable, fair and reasonable deal regardless of whether they represent the buyer or the seller of such companies. For instance, the built-in gains tax and installment sale rules are two considerations that must be evaluated when structuring the purchase or sale of a S firm.
Publication Name: Practical Tax Strategies
Subject: Law
ISSN: 0040-0165
Year: 1999
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Tax treatment of insurance premiums: economic performance requirements and captive insurance opportunities
Article Abstract:
Corporations can protect the tax deductibility of their insurance premiums through strategies including the use of captive insurance companies. The IRS proposed economic performance rules that limit deductibility to when corporations have actually paid insurers. However, the recurring item exception in IRC 461(h)(3) provides a means for safeguarding deductibility. Captive insurance companies, involving a corporation's insurance or reinsurance of taxpayers with a beneficial ownership interest, have likewise been used in the US and other countries to maintain deductibility.
Publication Name: Journal of Corporate Taxation
Subject: Law
ISSN: 0094-0593
Year: 1992
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Exclusions from income for qualified individuals employed outside the United States
Article Abstract:
IRC Section 911 allows US citizens and resident aliens whom their employers have sent abroad to obtain income tax deductions from the foreign earned income exclusion and the housing cost amount exclusion. As much as $70,000 of income earned outside the US can be deducted. Foreign housing expenses are fully deductible provided the taxpayer is not self-employed. However, Section 911 restricts these deductions to taxpayers who can prove that their tax home is in a foreign country where they have been present for a considerable time.
Publication Name: Journal of Corporate Taxation
Subject: Law
ISSN: 0094-0593
Year: 1993
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