Individuals

Corporations

Estates & trusts

Partnerships & LLC's

Accounting Periods & Methods

Bankruptcy, Insolvency & Debt Discharge

Charitable Contributions

Compensation & Employee Benefits

Deductions and Credits

Estate & Gift

International

Miscellaneous

Nontaxable Exchanges

Real Estate

Sales and Exchanges

Tax Returns, Examinations & IRS Procedure

This library contains hundreds of high-quality technical tax memoranda on a wide variety of topics. The memoranda are organized by topics and are fully word-searchable. This library is a rich resource of already-solved tax problems. Use it as a starting point for your own research.

The Tax Resource Group Memo Library Category: Corporate Taxation Accumulated Earnings Tax; Amount of Earnings Accumulated Without Imposition of Tax, Rules of Thumb; IRC: 531. Adoption of Fiscal Year; Filing an Invalid Tax Return: Affect on Tax Year; IRC: 441. Alternative Minimum Tax; ACE Adjustment--Installment Sales; IRC: 56(g)(4)(D)(iv), 453, 336(a). Alternative Minimum Tax; Effect of Difference in Accounting Methods; IRC: 56(g)(4)(B). Below Market Loans; Below Market Loans Between Brother-Sister Corporations, Imputed Interest, Possible Recharacterization of Loan; IRC: 7872. Cancellation of Indebtedness Income; Various Issues; IRC: §108. Capital Contributions; Guaranty Matter; IRC: 166(b). CFC Stock, Sale of; Avoidance of CFC Rules; IRC: 1248. Common Paymaster Rules; Requirements of Common Paymaster Rules; IRC: 3121(s). Constructive Dividends; Divorcing Couple Selling Closely-Held C Corporation; IRC: 301. Controlled Group of Corporations; Effect of Stock Gifts to Adult Offspring, Attribution Rules; IRC: 1563. Conversion of S Corporation to LLC; Basis of Assets Contributed to Newly-Formed LLC; IRC: 336(b), 723, 334, 7701(g). Conversion of S Corporation to LLC; Effect of Debt Assumption on Shareholder Liquidation Gain; IRC: 331, 358. Corporate Liquidation; Proper Corporate Level Treatment of Shareholder Loan; IRC: 61(a)(12), 118, 108. Corporate Officer--Employee vs. Independent Contractor; Amounts Paid to Mexican National; IRC 3121(d)(1), 3306(i), and 3401(c). Debt Discharge; Constructive Ownership and NOL; Contingent Liabilities in Relation to Insolvency Rules of Section 108; IRC: 382, 318(a)(1); 108(d)(3). Debt Discharge; S Corporation--Debt Forgiveness Issues; IRC: 61(a)(12), 108; 267; 1367(b)(2). Disability Insurance Plan; Excludability from Employee's Income and Deductibility by Corporation; IRC: 106, 162(a). Dividend Withholding Issue; Amounts Paid to Mexican National; IRC 1441. Dividends Received Deduction; Dividends Attributable to a Foreign Sales Corporation; IRC: 245, 246(b), 172(d)(5). Foreign Corporations, Income Producing Assets in U.S. Controlled Foreign Corporation; Foreign Corporation, Sourcing of Rental Income, Dividend Withholding, Repatriation Issues; IRC: 882(a), 864(c)(4), 881(a)(1), 861. Formation; Stock for Services; IRC: 83. Gift or Compensation?; Gift of Stock in Commercial Context; IRC: 61, 102, 311(b) and 336. Ignoring a Corporate Entity; Piercing the Corporate Veil; IRC 61. Incorporation of Partnership; Effect of Alternative Methods of Incorporation; IRC: 351, 368(c). Installment Liquidation; S Corporation Installment Liquidation--Time Period Limitations; IRC: 453(h), 453(B)(h), 331. Interest Expense; Interest on Debt to Carry S Corporation Stock; IRC: 1366(d)(1), 1367. Jobs Tax Credits Carryover; Unused Job Tax Credits, Survival of Section 196 Carryover on Termination of S Election; IRC: 196, 1371(b). Liquidations; Installment Sale in Conjunction with Liquidation; IRC: 336, 331, 453. Losses; 1244 Stock Loss, Manner of Disposition; IRC: 1244. Losses, Section 1244 Stock; Contribution to Insolvent Corporation; IRC: 1244. Medical Savings Account (MSA); MSA for Partners and S Corporation Shareholders; IRC: 105, 106, 1372(a), 707(c). Merger/Accounting Methods; Survival of Method of Accounting After Merger; IRC 381. Merger/NOLs; Survival of Tax Attributes After Merger Between Commonly Controlled Entities; IRC 381, 382. Merger of S Corporations; Effect of Merger on Basis-suspended Losses; IRC: 1366(d), 368(a)(1)(A), 381. Multiple Corporations; Controlled Groups; IRC: 1561, 1563, and 179. Multiple Corporations; Controlled Groups; IRC: 1561, 1563, and 179. Net Operating Loss; Contribution of Profitable Proprietorship to Loss Corporation; IRC: 351, 382, 269. Personal Holding Company; Royalties Defined/PHC Ramifications of Domestic Corporation with Foreign Shareholders; IRC: 543(a), 542(c)(7), 552(a)(2). Personal Holding Company; Tax-Exempt Interest as PHC Income; IRC: 103, 543, 61. Personal Holding Company Income; Effect of Liquidating Distribution on UPHCI; IRC: 562(b)(1), 316(b)(2)(B). Personal Service Corporation; NOL Carryback; IRC: 172; 280H(e); 444. Personal Service Corporation; Personal Service Corporation, Definition of; IRC: 448, 11. Property, Sale of; Comments on Suggestions to Shelter Property with Very Low Tax Basis; IRC: . Purchase of Company; Various Issues; IRC: 108, 382, 1271, 1001. Reasonable Compensation; Accumulated Earnings Tax Issue; IRC: 162, 531. Redemption; Employee Buyout of Sole Shareholder; IRC: 302. Redemption of Stock; Redemption of Stock in Connection with Divorcing Spouses; IRC: 1041, 302(b)(3). Redemptions, Complete Termination of Interest; Installment Note and Security Features as Continuing Interest; IRC: 302(b)(3), 302(c)(2), 318. Redemptions, Retention of Control, Escrow Arrangements; IRC 302(b)(3). Reorganization; Boot in Tax-Free Reorganizations; IRC: 368(a)(2)(B), 361(b), 302(b)(2). Reorganization; Deduction of Target's Accrued Expenses (Part A); Sections: 461(h). Reorganization; Deduction of Target's Accrued Expenses (Part B); Sections: 461(h). Reorganization; D-Reorganizations; IRC: 355, 368(a)(1)(D). Reorganization; D-Reorganization with Boot vs. Split-Off and Redemption; 368(a)(1)(D), 355, 302(b). Reorganization; F Reorganization; IRC: 368(a)(1)(F). Reorganization; Requirements for D-Reorganization Status; IRC: 368, 355. Reorganizations; Spin-off and Subsequent Merger of Spun-Off Business, Morris Trust Issues; IRC: 355, 368. Restoration of S Corporation Debt Basis; Exception to General Basis-Timing Rule; IRC: 1367(b)(2)(B). S Corporation; Automobile Reimbursements; IRC: 163(h)(2)(A). S Corporation; Basis of Bad Debt, Restoration of; Distribution Issues; IRC: 1367(b)(2)(B), 1368. S Corporation; Built-in Gains Tax, TRA 86 and TAMRA Transition Rules; IRC: 1374. S Corporation; Post-Termination Transition Period; IRC: 1371. S Corporation; Research Credit; IRC: 41(g), 53. S Corporation; S Corporation Back-to-Back Loan; IRC: 1362. S Corporation; S Corporation, Election after Termination, Successor Corporations; IRC: 1362(g). S Corporation; S Corporation Foreign Subsidiary Issues; IRC: 1361(b). S Corporation; S Corporation Reasonable Compensation Requirement; IRC: 3121. S Corporations, Built-In Gains Tax; Attorney's Contingent-Fee Case Inventory Present at Election of S Status; IRC: 1374. S Corporation--Capital Contributions; S Corporation Stock Options, Second Class of Stock; IRC Sections: 1361. S Corporation Contribution; S Corporation Contribution/Distribution of Appreciated Property; IRC: 351. S Corporation Liquidation; S Corporation Built-In Gains Tax; IRC: 1374, 1375. S Corporation Termination; Effect of Revocation: Gain Recognition as a Result of Losses in Excess of Stock Basis; IRC: 1362. S Corporation with C Corporation E&P; Tax Ramifications: Draft Letter to Client; IRC: 1368, 1375. Sale of Stock by Bankrupt Shareholder; COD Income at Corporate Level; IRC: 382, 108(e)(8), 61(a)(12). Section 179; Purchase of Assets from Related Parties; IRC: 179. Section 382 ; Application of Section 382, Rescission of Stock Sale; IRC: 382. Section 382; Various Section 382 Matters; IRC: 108, 368, 382. Section 481(a) Adjustment; Effect of Conversion to S Corporation; IRC: 481(a) Section 1244 Stock; Discussion of Applicability of Section 1244; IRC: 1244. Stock Redemptions; Various Issues; IRC: 302, 318, 311, 166, 368. Stock vs. Asset Purchase; Basis Adjustment; IRC: 197, 332, 338. Tax Return Election; Termination of Section 444 Election; IRC: 444. Taxability of Government Subsidies; Grant From City to Make Capital Improvements; IRC: 118(a). Transfer of Assets; Effects of Transfer of Assets from Corporation to Partnership; IRC: 501(c)(3), 1060, 168(f)(5)(B)(iii). Transfer of Clientele Between Commonly Controlled Corporations; Constructive Dividend of Goodwill; IRC: . Transfer to Controlled Corporation; Section 351 Incorporation, Section 357(c) Gain, Tax Accounting Issues; IRC 351, 357(c).