IRS hot button: Deductible management fees vs. disguised distributions

Description

Abstract: The U.S. Tax Court recently ruled that management fees a corporation paid to shareholders over a three-year period weren’t deductible; instead, they represented disguised distributions. This article summarizes the key points of this decision and explains why it could be relevant outside of a federal tax context. Aspro, Inc. v. Commissioner, TC Memo 2021-8.