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.
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November 2024 - The Tax Adviser
- Magazine
- November 2024

corporations & shareholders
SPECIAL INDUSTRIES

The CHIPS Actโs 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.
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Client advisory service for business owners
Clint Costa, Senior Wealth Strategist, Choreo, discusses how CPAs can add value to business owner clients.
TAX CLINIC
CONSOLIDATED RETURNS
credits against tax
expenses & deductions
GROSS INCOME
partners & partnerships
procedure & administration
COLUMNS
TAX PRACTICE RESPONSIBILITIES
CAMPUS TO CLIENTS
CASE STUDY
employee benefits & pensions
Profits interests: The most tax-efficient equity grant to employees
By granting them a profits interest, entities taxed as partnerships can reward employees with equity. Mistakes, however, could cause challenges from taxing authorities.