IRS Rules on Telecom Coop Sale of Stock

A recent IRS private letter ruling addresses whether a cooperative’s gain on sale of stock resulted in patronage or non-patronage income. This particular ruling follows many others that focus on the reason for acquiring the asset.

In Year 1, CORP

Patronage Determinations: Patronage-Sourced Income and Expenses

Taxable cooperatives – including Subchapter T cooperatives and taxable rural telephone and electric cooperatives – must determine whether income and expenses are considered patronage-sourced or not.  This is called patronage determination.  It is critical to taxable cooperatives because it determines …

AHC Attorney David Cook Presents on Capital Credits and Cooperative Tax

AHC attorney David Cook will present at the National Telecommunications Cooperative Association’s Finance and Accounting Conference concerning two important topics for telecommunications and telephone cooperatives.  He will discuss “Strategies for Managing Capital Credits” and “Handling Large Gains and Losses.”  Here …

AHC Cooperative Tax Brief: Telephone Cooperative’s Sale of Subsidiary

In the latest cooperative tax ruling, the Service ruled that a cooperative’s (“Cooperative”) gain on sale of stock in corporations that offered services to Cooperative’s members was patronage-sourced.  The ruling was important to Cooperative because it expected to fail the …