As part of the 2017 tax reform bill, Congress passed new Section 199A, which authorizes a deduction for “specified agricultural or horticultural cooperatives.” As discussed… Read More »IRS Issues Sec. 199A Guidance for W-2 Limitation
In a new ruling, the Service considered the period of historical patronage business that should be used to calculate the gain on a liquidation sale. Coop was a… Read More »New IRS Ruling: The Timing of Patronage Business for Allocations
Many cooperatives provide a range of services to their members. Sometimes these services are provided through subsidiaries. Each cooperative must choose the right mix of… Read More »Cooperative-Subsidiary Consolidation Issues
In a prior Cooperative Tax Post, we discussed the Service’s trend of permitting cooperatives to satisfy notification requirements of Subchapter T by modern transmission methods. … Read More »IRS Approves Patrons’ “Written Consent” by Website
To view this Cooperative Tax Brief in PDF, click here. Allocation and distribution of earnings is a fundamental tenant of cooperative operation. It is not… Read More »IRS Addresses Cooperatives’ Allocation Methods
Read this Cooperative Tax Brief in PDF format. As shown in prior posts, the most interesting rulings are those that involve the interplay of cooperative… Read More »Cooperative Exchanges Preferred Stock for QWNAs
In a prior post, we discussed the interaction of Subchapter T (governing cooperatives) and Subchapter M (governing REITs). As explained in the prior post, REITs… Read More »REIT’s Receipt of Patronage Dividends is Excluded from REIT Income Tests
View the PDF version of this Cooperative Tax Brief here. When it comes to financial losses, many cooperatives are uncertain how to handle them. Because… Read More »Handling Cooperative Losses
To view this AHC Cooperative Tax Brief as a PDF, click here. The IRS has rejected an organization’s application for exemption under Section 501(c)(12), even… Read More »Cooperative Tax Brief: Federated Telecommunications Cooperative Denied Exemption
Developers are constantly looking for ways to find capital for their energy development projects. They have solicited all sorts of capital, including banks, angel investors, private equity investors, private development bonds, and other sources. One other potential source of capital for certain types of projects is a Real Estate Investment Trust (REIT). A recent IRS private ruling discusses the limitations and potential viability of REITs for funding energy development projects. Read More »IRS Ruling Address Power Generation by REITs
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