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
cThese proposed regulations provide guidance to cooperatives to which sections 1381 through 1388 of the Internal Revenue Code (Code) apply (Cooperatives) and their patrons regarding the deduction for qualified business income (QBI) under section 199A(a) of the Code as well as guidance to specified agricultural or horticultural cooperatives (Specified Cooperatives) and their patrons regarding the deduction for domestic production activities under section 199A(g) of the Code.
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
Attorney David Cook will be presenting a “Tax Update for Cooperatives” at the NTCA 2015 Finance & Accounting Conference. Click here for more details. NTCA… Read More »Telephone Cooperative Tax Update Presented by David Cook