Irc Section 118

The tcja had a major impact on irc section 118 as it relates to contributions by non shareholders.

Irc section 118. 118 d cross references. The amendments made by this section amending this section and sections 6501 and 6511 of this title shall apply to expenditures with respect to which the second taxable year described in former section 118 b 2 b of the internal revenue code of 1986 formerly i r c. 1954 ends after december 31 1984.

118 c regulations the secretary shall issue such regulations or other guidance as may be necessary or appropriate to carry out this section including regulations or other guidance for determining whether any contribution constitutes a contribution in aid of construction. Contributions to the capital of a corporation on westlaw findlaw codes are provided courtesy of thomson reuters westlaw the industry leading online legal research system. Beyond the clear and plain meaning of i r c.

118 which does not extend exclusion treatment of income to non corporate entities for capital contributions the legislative history regarding these provisions unambiguously indicates that congress limited the scope of the statutory provisions to businesses operating in corporate form because that is precisely what the pre existing case law addressed. In the case of a corporation section 118 provides an exclusion from gross income with respect to any contribution of money or property to the capital of the taxpayer.