- April 9, 2024A recent IRS ruling addresses how one taxable telephone cooperative managed to avoid a devastating taxable gain on the sale…
- September 5, 2023In a recent private letter ruling, the Service addressed a cooperative's reorganization into a for-profit corporation. The transaction qualified under…
- July 18, 2023In a prior post, I addressed new regulations from Treasury Department addressing clean energy tax credit options. The post discussed…
- July 16, 2023In a recent ruling, the Service addressed a telecom cooperative that divested its cellular business to focus on broadband services.…
- January 14, 2021In a new ruling, the Service considered the period of historical patronage business that should be used to calculate the gain…
- January 3, 2020cThese proposed regulations provide guidance to cooperatives to which sections 1381 through 1388 of the Internal Revenue Code (Code) apply…
- September 7, 2017Many cooperatives provide a range of services to their members. Sometimes these services are provided through subsidiaries. Each cooperative must…
- March 29, 2017In a prior Cooperative Tax Post, we discussed the Service’s trend of permitting cooperatives to satisfy notification requirements of Subchapter…
- February 10, 2017Cooperative tax professionals occasionally consider whether patronage dividends, such as QWNAs, are considered equity or debt. The issue was central…
- May 31, 2016To view this Cooperative Tax Brief in PDF, click here. Allocation and distribution of earnings is a fundamental tenant of…
- May 27, 2016Read this Cooperative Tax Brief in PDF format. As shown in prior posts, the most interesting rulings are those that…
- May 19, 2016In a prior post, we discussed the interaction of Subchapter T (governing cooperatives) and Subchapter M (governing REITs). As explained…
- May 13, 2016View the PDF version of this Cooperative Tax Brief here. When it comes to financial losses, many cooperatives are uncertain…
- December 12, 2014Real Estate Investment Trusts and Cooperatives’ Patronage Dividends Some of the more interesting cooperative tax cases involve the interplay of…
- September 19, 2014To view this AHC Cooperative Tax Brief as a PDF, click here. The IRS has rejected an organization’s application for…
- December 3, 2013Developers are constantly looking for ways to find capital for their energy development projects. They have solicited all sorts of…
- November 12, 2013Cooperatives May Offset Bad Debt with Capital Credit Balances Like for-profit companies, cooperatives encounter bad debt of members and patrons. …
- September 16, 2013Cooperative’s Consolidation and Liquidation of Subsidiaries [To view this post in the typical Cooperative Tax Brief format, click here.] Like…
- March 30, 2013Cooperatives have been given conflicting guidance from the IRS concerning the proper treatment of discounting of capital credits. Specifically, some…
- December 31, 2012A prior blog post discussed a private ruling by the service regarding the allocation of purchase price among the assets…
- December 21, 2012The Service recently denied exemption to an organization that sought exemption under Section 501(c)(12) as a mutual ditch and irrigation…
- October 14, 2012C&A attorneys have been closely following lawsuits against cooperatives' capital credit management. We recently developed an updated summary of the…
- August 11, 2012In another lawsuit concerning cooperatives' capital credit practices, a North Carolina trial court ruled in favor of a cooperative that…
- August 7, 2012Earlier this past July, the Texas Court of Appeals ruled on important aspects of the cooperative lawsuit concerning Denton County…
