ARTICLE
17 January 2019

Planning For Business Exits From C Corporations; Intrafamily Business Transactions; Other Developments

TC
Thompson Coburn LLP

Contributor

For almost 90 years, Thompson Coburn LLP has provided the quality legal services and counsel our clients demand to achieve their most critical business goals. With more than 380 lawyers and 40 practice areas, we serve clients throughout the United States and beyond.
Lower C corporation income tax rates have increased attention to the Code § 1202 exclusion for gain on sale of stock.
United States Corporate/Commercial Law
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Webinar

Lower C corporation income tax rates have increased attention to the Code § 1202 exclusion for gain on sale of stock. We will discuss how that and related provisions work, how they compare with other business exit strategies, and a recent Tax Court case that informs intrafamily business sales and loans. We also mention a new favorable IRS position regarding deducting charitable contributions that generate state tax credits for business owners.

You will learn:

  • How the Code § 1202 exclusion works, how it applies when a business changes from another entity to a C corporation, how it informs a C corporation's business structure, and how it compares to other business exit strategies.
  • How to move from corporate status to a partnership once the tax benefits of being a C corporation has run its course.
  • The impact of Dynamo Holdings Ltd. Partnership v. Commissioner, T.C. Memo. 2018-61, which addresses sales and loans between businesses owned by related parties. It limits the application of a taxpayer-friendly 2009 case on business transfers but also provides hope for those with relaxed documentation of loans.
  • How states' reactions to 2017 tax reform imposing a limit on state income tax and personal property tax deductions led to the IRS attacking state tax credits awarded for charitable contributions, which ironically resulted in a Revenue Procedure that provides favorable rules when businesses make those contributions.

This webinar is an oral presentation and elaboration on Steve Gorin's Business Succession Solutions 4th quarter 2018 newsletter.

CLE

Approved for 1.5 hour general CLE credit in California and Illinois

Approved for 1.8 hours of general CLE credit in Missouri

Presenter:

Steve Gorin

*Please note that this is a 90-minute presentation

Tuesday, January 29, 2019

Begins at 12:00 PM Central Time

To register for this webinar please click here

The content of this article is intended to provide a general guide to the subject matter. Specialist advice should be sought about your specific circumstances.

ARTICLE
17 January 2019

Planning For Business Exits From C Corporations; Intrafamily Business Transactions; Other Developments

United States Corporate/Commercial Law

Contributor

For almost 90 years, Thompson Coburn LLP has provided the quality legal services and counsel our clients demand to achieve their most critical business goals. With more than 380 lawyers and 40 practice areas, we serve clients throughout the United States and beyond.
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