March 2014 - The Tax Adviser

Final regulations under Sec. 336(e) provide special rules for S corporations and their shareholders to make an election to treat a sale or disposition, including a distribution of control of a corporation’s stock of a qualified subsidiary, as a disposition of all the subsidiary’s assets.

This article is Part I of a two-part article covering recent developments affecting taxation of individuals, including regulations, cases, and IRS guidance.

This article examines income tax issues that commonly arise in connection with the conveyance of pipeline easements and surface sites and identifies planning opportunities.