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Tax capital accounts are partners' "Outside Basis" (however, unlike outside basis, the partnership's recourse and nonrecourse liabilities are not included in partners' tax-basis capital accounts) and under Section 722 are initially determined by reference to the partner's contributed cash amount and the adjusted basis of the contributed property.
If the taxpayer wants to change a tax accounting method, section 446 of the Internal Revenue Code requires the taxpayer to obtain the consent of the Internal Revenue Service. There are two kinds of changes: obtaining a letter of approval from the IRS, and obtaining a series of more routine changes, each of which is an automatic change.
Section 355 allows a corporation with one or more businesses that have been actively conducted for five years or more to make a tax-free distribution of the stock of a controlled subsidiary provided that the transaction is being carried out for a legitimate business purpose and is not being used principally as a device to bail out earnings and ...
Unrelated Business Income Tax (UBIT) in the U.S. Internal Revenue Code is the tax on unrelated business income, which comes from an activity engaged in by a tax-exempt 26 U.S.C. 501 organization that is not related to the tax-exempt purpose of that organization.
Simply an operation having no business or corporate purpose-a mere device which put on the form of a corporate reorganization as a disguise for concealing its real character, and the sole object and accomplishment of which was the consummation of a preconceived plan, not to reorganize a business or any part of a business, but to transfer a ...
Small business owners, independent contractors and gig workers soon will be getting 1099-K tax forms if they used any payment platform on which they had at least $5,000 in business transactions in ...
Everyone's favorite time of year is right around the corner: Tax Day! Filing and paying taxes is a part of life for everyone who works in the U.S. Making sure you file your tax return correctly is...
According to a 2011 report by the Internal Revenue Service Advisory Council ("IRSAC") Office of Professional Responsibility ("OPR") Subgroup, [17] Circular 230 sets forth ethical standards which are generally meant to apply to "willful" misconduct. Willful misconduct is generally described as "the intentional violation of a known legal duty."