Proposed regulations would treat S corporation suspended losses as nontransferable

Article Abstract:

IRS proposed regulations regarding the nontransferability of suspended losses in the context of S corporation stock transfers is particularly important in IRC section 1041 transfers between spouses. Suspended losses are those losses which exceed shareholders' bases and which shareholders may carry forward until the time when their bases are increased enough to allow loss deductions. Disallowance of loss transfer in the spousal context is inappropriate and conflicts with the policy underlying section 1041 which treats spousal transfers as tax-neutral events.

United States, Corporate Tax Deductions & Exemptions, Personal Income Tax Deductions, Corporate taxes, Securities, Personal income tax, S corporations, Loss deductions, Basis (Taxation)

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When will business investigatory expenditures be amortizable start-up costs?

Article Abstract:

Costs incurred for investigations as part of generalized searches preliminary to business acquisitions are not deductible or amortizable to the extent attributable to nonacquired businesses. The IRS in Technical Advice Memorandum 9825005 found such costs ineligible for IRC section 195 amortization treatment. The ruling is too narrow and does not properly reflect the legislative intent underlying the statute.

Tax Deductions & Exemptions, Taxation, Venture capital, Internal auditing, Amortization

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