Taxable cooperatives – including Subchapter T cooperatives and taxable rural telephone and electric cooperatives – must determine whether income and expenses are considered patronage-sourced or… Read More »Patronage Determinations: Patronage-Sourced Income and Expenses
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
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. … Read More »AHC Attorney David Cook Presents on Capital Credits and Cooperative Tax
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
Cooperative tax professionals occasionally consider whether patronage dividends, such as QWNAs, are considered equity or debt. The issue was central to a recent decision by… Read More »Patronage QWNAs as Debt or Equity?
The IRS is seeking comments on Form 1120-C, which is the tax return required for most Subchapter T cooperatives other than Section 521 agricultural cooperatives.… Read More »IRS Seeks Comments on Subchapter T Cooperatives’ Tax Return
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
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