Marriott (MAR) downgraded to In Line from Outperform at Evercore ISI with analyst Rich Hightower saying approaching Q1 earnings season, the analyst finds himself "incrementally negative" on hotel stocks overall - and even more so with respect to the C-Corps
than the REITs - given the sector's substantial recent outperformance against the relevant benchmarks, coupled with no obvious shift in fundamentals over the last 60-90 days.
The final ruling states that "the Commission recognizes that it will have the burden, in any proceeding it initiates under NGA section 5 to support complete elimination of the existing tax allowance." The FERC further states "we encourage pass-through entities to provide any information regarding their particular circumstances or ownership structures that they consider relevant in assessing any potential United Airlines double-recovery issue." While these comments seem to represent a friendlier approach from the FERC, Enable Midstream Partners, LP (ENBL) recently filed a rate case for its MRT pipeline, and its request to include an ITA on the basis that it is ~86% owned by C-corps
was surprisingly denied.
One frequent misunderstanding about corporations involves so-called C corporations and S corporations (or C-corps
and S-corps), and whether owners have to choose to form their business as a C-corp
Business people lately are eager to form or continue as C-corporations in light of lower taxes for these entities under new laws, but accountants said the devil may be in the details, potentially leading to double taxation.<br />The new tax code dropped taxes for C-corps
from 35 percent to 21 percent, pleasing firms already with that structure and attracting attention from other companies.
A/E/C companies who are C-Corps
will benefit from the tax rates being lowered to 21 percent and will also benefit from the repeal of the corporate alternative minimum tax.
tax reform legislation last December could spur additional alternative IMs to convert from partnerships to C-Corps
conversion would likely result in higher taxes as incentive income (carry) would be subject to taxation at the corporate level.
Effectively, they are all the businesses that are not corporations or C-corps
; these include the vast majority of all American businesses and franchises.
The Potlatch union will convert Deltic, which Covey described as "one of the few remaining C-corps
" in the timber industry, to a REIT, ensuring that the combined company achieves tax advantages.
The tax increase would have impacted only C-corps
and was directed primarily at large out-of-state companies.
For example, he said, some major car dealers in Oregon are C-corps
and would face substantially higher taxes under Measure 97.
In an op-ed for the Washington, D.C.-centric The Hill, ABC Immediate Past Chair Pamela Volm called on stakeholders to create a tax environment that encourages growth for both big and small businesses: "While there seems to be a general consensus that our tax system needs fundamental reform, some in Washington, including President Obama, have proposed reforms chiefly concerned with lowering the corporate rate--despite the fact that so-called C-corps
make up just five percent of all business entities and account for less than half of the private sector workforce.