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Report on Corporate Distributions and Adjustments to Accompany Subchapter C Advisory Group Proposed Amendments Received by the Subcommittee on Internal Revenue Taxation and Transmitted to the Committee on Ways and Means, U.S. House of Representatives from the Advisory Group on Subchapter C of the Internal Revenue Code of 1954

Report on Corporate Distributions and Adjustments to Accompany Subchapter C Advisory Group Proposed Amendments Received by the Subcommittee on Internal Revenue Taxation and Transmitted to the Committee on Ways and Means, U.S. House of Representatives from the Advisory Group on Subchapter C of the Internal Revenue Code of 1954
Author: United States. Congress. House. Committee on Ways and Means
Publisher:
Total Pages: 88
Release: 1957
Genre: Corporations
ISBN:

Download Report on Corporate Distributions and Adjustments to Accompany Subchapter C Advisory Group Proposed Amendments Received by the Subcommittee on Internal Revenue Taxation and Transmitted to the Committee on Ways and Means, U.S. House of Representatives from the Advisory Group on Subchapter C of the Internal Revenue Code of 1954 Book in PDF, ePub and Kindle


Reasonable Compensation

Reasonable Compensation
Author: Anne E. Moran
Publisher:
Total Pages:
Release:
Genre: Corporations
ISBN: 9781558718449

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" ... analyzes the issues relating to the deduction by an employer for a "reasonable allowance" under [section] 162(a) for compensation paid with regard to personal services rendered. It discusses in depth the factors applied in determining reasonableness, the necessity for the actual performance of services, situations where a deduction for reasonable compensation is not allowable, and other aspects of reasonable compensation. Various tax planning and controversy considerations also are discussed"--Portfolio description (p. iii).


Federal Taxation of S Corporations

Federal Taxation of S Corporations
Author: Deborah H. Schenk
Publisher: Law Journal Press
Total Pages: 858
Release: 2017-09-28
Genre: Business & Economics
ISBN: 9781588520333

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The book features: a detailed analysis of the regulations on eligibility requirements; a discussion of the passive activity rules; and a valuable chapter on financially distressed S corporations.


Cryptocurrency

Cryptocurrency
Author: Congressional Research Service
Publisher: Independently Published
Total Pages: 34
Release: 2019-01-03
Genre:
ISBN: 9781793088772

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Cryptocurrencies are digital money in electronic payment systems that generally do not require government backing or the involvement of an intermediary, such as a bank. Instead, users of the system validate payments using certain protocols. Since the 2008 invention of the first cryptocurrency, Bitcoin, cryptocurrencies have proliferated. In recent years, they experienced a rapid increase and subsequent decrease in value. One estimate found that, as of August 2018, there were nearly 1,900 different cryptocurrencies worth about $220 billion. Given this rapid growth and volatility, cryptocurrencies have drawn the attention of the public and policymakers. A particularly notable feature of cryptocurrencies is their potential to act as an alternative form of money. Historically, money has either had intrinsic value or derived value from government decree. Using money electronically generally has involved using the private ledgers and systems of at least one trusted intermediary. Cryptocurrencies, by contrast, generally employ user agreement, a network of users, and cryptographic protocols to achieve valid transfers of value. Cryptocurrency users typically use a pseudonymous address to identify each other and a passcode or private key to make changes to a public ledger in order to transfer value between accounts. Other computers in the network validate these transfers. Through this use of blockchain technology, cryptocurrency systems protect their public ledgers of accounts against manipulation, so that users can only send cryptocurrency to which they have access, thus allowing users to make valid transfers without a centralized, trusted intermediary. Money serves three interrelated economic functions: it is a medium of exchange, a unit of account, and a store of value. How well cryptocurrencies can serve those functions relative to existing money and payment systems likely will play a large part in determining cryptocurrencies' future value and importance. Proponents of the technology argue cryptocurrency can effectively serve those functions and will be widely adopted. They contend that a decentralized system using cryptocurrencies ultimately will be more efficient and secure than existing monetary and payment systems. Skeptics doubt that cryptocurrencies can effectively act as money and achieve widespread use. They note various obstacles to extensive adoption of cryptocurrencies, including economic (e.g., existing trust in traditional systems and volatile cryptocurrency value), technological (e.g., scalability), and usability obstacles (e.g., access to equipment necessary to participate). In addition, skeptics assert that cryptocurrencies are currently overvalued and under-regulated. The invention and proliferation of cryptocurrencies present numerous risks and related policy issues. Cryptocurrencies, because they are pseudonymous and decentralized, could facilitate money laundering and other crimes, raising the issue of whether existing regulations appropriately guard against this possibility. Many consumers may lack familiarity with cryptocurrencies and how they work and derive value. In addition, although cryptocurrency ledgers appear safe from manipulation, individuals and exchanges have been hacked or targeted in scams involving cryptocurrencies. Accordingly, critics of cryptocurrencies have raised concerns that existing laws and regulations do not adequately protect consumers dealing in cryptocurrencies. At the same time, proponents of cryptocurrencies warn against over-regulating what they argue is a technology that will yield large benefits. Finally, if cryptocurrency becomes a widely used form of money, it could affect the ability of the Federal Reserve and other central banks to implement and transmit monetary policy, leading some observers to argue that central banks should develop their own digital currencies (as opposed to a cryptocurrency); others oppose this idea.


Estate Planning Strategies Designed for the 'C' Corporation

Estate Planning Strategies Designed for the 'C' Corporation
Author: Jeffrey A. Galant
Publisher:
Total Pages:
Release: 2006
Genre:
ISBN:

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Estate planners need to be mindful of the potential for double taxation when shares of a C corporation are transferred, and of the various strategies available to ameliorate the tax impact. The Supreme Court in 1935 in the General Utilities case laid the foundation for the 1939 and 1954 code provisions that did not tax to a distributing corporation in kind distributions to shareholders. This allowed for the disposition of a business operated in corporate form at the cost of only a single level of tax. The 1986 Tax Reform Act changed the landscape by providing that in kind liquidating distributions were taxable to the distributing corporation. Hence, the double tax.The strategies discussed include treating the corporation as a nominee of the taxpayer rather than as the taxpayer, as described in Bollinger; structuring the sale of the business so that a substantial portion of the goodwill being acquired is considered the property of a shareholder who is an individual rather than of the corporation, as explained in Martin Ice Cream; using a charitable remainder trust to facilitate succession planning for a family business, as suggested in certain IRS rulings; employing the National Starch transaction and section 351 to preserve the step up in basis of the shares of an elderly stockholder, and engaging in a leveraged ESOP transaction to defer if not eliminate the business owner's gain on the sale of the corporation's shares and allowing the corporation to facilitate the purchase of such shares by deducting 100% of the purchase price.