The built-in gains tax - the IRS issues proposed regs

Article Abstract:

The IRC section 1374 proposed regulations provide guidance for the application of the built-in gains tax that was enacted by Congress to prevent corporations from avoiding double tax on appreciated property sales. The built-in gains tax affects S corporations that converted to S status after 1987 but there has been minimal guidance to the section's application. The proposed regulations determine net recognized built-in gain, reduce the gain by losses, apply the current tax rate and determine the final tax. However, unrecognized gain rules are still confusing.

S corporations

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Who is taxed on a divorce-related stock redemption?

Article Abstract:

This article concerns the tax treatment of closely-held corporation stock redemptions in the context of divorce settlements. Several cases and IRS rulings discussing gain nonrecognition under IRC section 1041 are presented. Review of these conflicting authorities results in the conclusion that planning for such redemptions is difficult, but certain more obvious precautions may be taken.

Tax Law, Public Finance Activities, Securities, Close corporations, Closely held corporations, Divorce settlements, Stock redemption

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Proposed regulations provide guidance on the sale of a principle residence

Article Abstract:

The author discusses proposed regulations under IRC sections 121 and 1034, which simplify the tax treatment of principle residence sales and the recognition of gain.

House selling, Home selling

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