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.
Over the past year, we have been posting on the tax bill passed on December 22, 2017, as Public Law 115-97 (the “Original Act”). The… Read More »Tax Reform Act Impacts Cooperatives, Part V: New Developments for Cooperatives Under Section 199A
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
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
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
Real Estate Investment Trusts and Cooperatives’ Patronage Dividends Some of the more interesting cooperative tax cases involve the interplay of cooperative tax law, such as… Read More »Real Estate Investment Trusts and Cooperatives’ Patronage Dividends
To view this Cooperative Tax Brief in the traditional PDF format, click here. Introduction What counts as notice of patronage under Subchapter T? Traditionally, notices… Read More »Cooperative Tax Brief: Alternative Methods of Patronage Notification