Tax Section
What is an IC-DISC?
An interest charge domestic international sales corporation (“IC-DISC”) is a special tax exempted domestic corporation that qualifies under Sections 991…
The Basics of F Reorganizations
Among the tax-free reorganizations authorized by Section 368 is the F reorganization. Section 368(a)(1)(F) defines this type of reorganization as “a mere…
Remembering Bob Mendenhall
Bob Mendenhall, former Chair of the North Carolina Bar Association Tax Section, passed away on July 14, 2022, at the Charlotte Rehab Center, one day before…
What is an Investment Partnership?
As discussed in my January 12, 2022, blog post, Section 731(c) generally treats marketable securities as money in determining gain or loss on a distribution…
Quid Pro Quo: Charity Disclosure Requirements
Section 6115 imposes a disclosure requirement on charitable organizations that receive quid pro quo contributions in excess of $75. A quid pro quo…
Recent National Articles about North Carolina Tax Matters
There have been several recent national articles about North Carolina tax matters. 1. The May 11, 2022 issue of Taxes – The Tax Magazine has an article…
Golden Parachute Payments – Shareholder Approval Exception
Sections 280G and 4999 impose a 20% excise tax in addition to regular income taxes on individuals who receive an excess parachute payment upon a change of…
The Tax Section Returns to Kiawah Island for Memorial Day!
After a 3-year hiatus, the Tax Section returns to beautiful Kiawah Island, SC for its annual meeting and CLE program, May 27-29, 2022. The 3-day program…
New Proposed Rules for Group Tax Exemptions
Section 501(a) provides an exemption from income taxation for certain organizations. For decades, the IRS has provided a procedure allowing multiple…
Federal Income Tax Update: Part II
I. IRS Continues to Crack Down on S Corporation Disguised Wages. In Ward & Ward Company v. Commissioner, T.C. Memo. 2021-32, the Tax Court held payments…