Advertisement
Cover Image for November 2024
corporations & shareholders

Cleaning up intercompany debt

An intercompany loan between related corporations may be recharacterized as an equity contribution by the companiesโ€™ shareholders, resulting in a constructive dividend to the shareholders. This article focuses on a recent Tax Court case involving the proper characterization of purported intercompany loans between two S corporations.

SPECIAL INDUSTRIES
IMAGE BY TRYFONOV/ADOBE STOCK

The CHIPS Actโ€™s advantageous direct-pay election

This article summarizes the key features of the direct-pay election for the advanced manufacturing credit, which allows taxpayers to treat the credit as a direct payment against their federal income tax.