§118 — Contributions to the capital of a corporation

82 cases·14 followed·15 distinguished·1 questioned·1 criticized·1 overruled·50 cited17% support

(a)General rule

In the case of a corporation, gross income does not include any contribution to the capital of the taxpayer.

(b)Exceptions

For purposes of subsection (a), except as provided in subsection (c), the term “contribution to the capital of the taxpayer” does not include—

(1)

any contribution in aid of construction or any other contribution as a customer or potential customer, and

(2)

any contribution by any governmental entity or civic group (other than a contribution made by a shareholder as such).

(c)Special rules for water and sewerage disposal utilities
(1)General rule

For purposes of this section, the term “contribution to the capital of the taxpayer” includes any amount of money or other property received from any person (whether or not a shareholder) by a regulated public utility which provides water or sewerage disposal services if—

(A)

such amount is—

(i)

a contribution in aid of construction, or

(ii)

a contribution to the capital of such utility by a governmental entity providing for the protection, preservation, or enhancement of drinking water or sewerage disposal services,

(B)

in the case of a contribution in aid of construction which is property other than water or sewerage disposal facilities, such amount meets the requirements of the expenditure rule of paragraph (2), and

(C)

such amount (or any property acquired or constructed with such amount) is not included in the taxpayer’s rate base for ratemaking purposes.

(2)Expenditure rule

An amount meets the requirements of this paragraph if—

(A)

an amount equal to such amount is expended for the acquisition or construction of tangible property described in section 1231(b)—

(i)

which is the property for which the contribution was made or is of the same type as such property, and

(ii)

which is used predominantly in the trade or business of furnishing water or sewerage disposal services,

(B)

the expenditure referred to in subparagraph (A) occurs before the end of the second taxable year after the year in which such amount was received, and

(C)

accurate records are kept of the amounts contributed and expenditures made, the expenditures to which contributions are allocated, and the year in which the contributions and expenditures are received and made.

(3)Definitions

For purposes of this subsection—

(A)Contribution in aid of construction

The term “contribution in aid of construction” shall be defined by regulations prescribed by the Secretary, except that such term shall not include amounts paid as service charges for starting or stopping services.

(B)Predominantly

The term “predominantly” means 80 percent or more.

(C)Regulated public utility

The term “regulated public utility” has the meaning given such term by section 7701(a)(33), except that such term shall not include any utility which is not required to provide water or sewerage disposal services to members of the general public in its service area.

(4)Disallowance of deductions and credits; adjusted basis

Notwithstanding any other provision of this subtitle, no deduction or credit shall be allowed for, or by reason of, any expenditure which constitutes a contribution in aid of construction to which this subsection applies. The adjusted basis of any property acquired with contributions in aid of construction to which this subsection applies shall be zero.

(d)Statute of limitations

If the taxpayer for any taxable year treats an amount as a contribution to the capital of the taxpayer described in subsection (c)(1)(A)(i), then—

(1)

the statutory period for the assessment of any deficiency attributable to any part of such amount shall not expire before the expiration of 3 years from the date the Secretary is notified by the taxpayer (in such manner as the Secretary may prescribe) of—

(A)

the amount of the expenditure referred to in subparagraph (A) of subsection (c)(2),

(B)

the taxpayer’s intention not to make the expenditures referred to in such subparagraph, or

(C)

a failure to make such expenditure within the period described in subparagraph (B) of subsection (c)(2), and

(2)

such deficiency may be assessed before the expiration of such 3-year period notwithstanding the provisions of any other law or rule of law which would otherwise prevent such assessment.

(e)Cross references
(1)

For basis of property acquired by a corporation through a contribution to its capital, see section 362.

(2)

For special rules in the case of contributions of indebtedness, see section 108(e)(6).

  • Treas. Reg. §Treas. Reg. §1.118-1 Contributions to the capital of a corporation
  • Treas. Reg. §Treas. Reg. §1.118-2 Contribution in aid of construction
  • Treas. Reg. §Treas. Reg. §1.118-2(a) Special rule for water and sewerage disposal utilities—(1) In general.
  • Treas. Reg. §Treas. Reg. §1.118-2(b) Contribution in aid of construction—(1) In general.
  • Treas. Reg. §Treas. Reg. §1.118-2(c) Expenditure rule—(1) In general.
  • Treas. Reg. §Treas. Reg. §1.118-2(d) Adjusted basis—(1) Exclusion from basis.
  • Treas. Reg. §Treas. Reg. §1.118-2(e) Statute of limitations—(1) Extension of statute of limitations.
  • Treas. Reg. §Treas. Reg. §1.118-2(f) Effective date.
  • Treas. Reg. §Treas. Reg. §1.118-2(i) §1.118-2(i)

82 Citing Cases

DIST. CF Headquarters Corporation, Petitioner 164 T.C. No. 5 · 2025

Nonshareholder Contributions to Capital Section 118(a) generally excludes from gross income any contribution to the capital of a corporation. This includes contributions made by nonshareholders. Treas. Reg. § 1.118-1. The exclusion does not apply, however, to any money or other property transferred in consideration for goods or services rendered.5 Id.

FOLLOWED Robert Lewis Starer & Merle Ann Starer, Petitioners T.C. Memo. 2022-124 · 2022

In Saline Sewer we held that “the failure to report customer connection fees as income, and instead treat them as contributions to capital pursuant to section 118, is clearly not a timing issue.” See id at *9.

Accordingly, we hold that petitioners did not strictly comply with the requirement under section 170 and the regulations thereunder that the taxpayer obtain a CWA.

Contributions to the capital of a corporation.-- 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.

- 22 - [*22] Petitioner argues that it falls under one such exclusion: section 118(a),¹² which provides that, in general, "[i]n the case ofa corporation, gross income does not include any contribution to the capital ofthe taxpayer." As relevant in this matter, section 1.118-1, Income Tax Regs., provides: In the case ofa corporation, section 118 provides an exclusion from gross income with respect to any contribution ofmoney or property to the capital ofthe taxpayer. * * * Section 118 also applie

Ira & Tracy Nathel, Petitioner 131 T.C. No. 17 · 2008

W&N CAL of the $1,622 , 050 loan payments, petitioners ' August 30 , 2001, capital contributions to G&D and to W&N CAL were treated by petitioners as constituting income under section 1366 (a)(1) to G&D and W&N CAL (albeit as excludable income under section 118) and therefore as restoring or increasing under section 1367 (b)(2)(B) petitioners' respective tax bases in the outstanding loans each petitioner made to G&D and W&N CAL as follows : Each Petitioner's Tax Bases in Loans To G&D and W&N CAL

Sheldon & Ann M. Nathel, Petitioner 131 T.C. No. 17 · 2008

W&N CAL of the $1,622 , 050 loan payments, petitioners ' August 30 , 2001, capital contributions to G&D and to W&N CAL were treated by petitioners as constituting income under section 1366 (a)(1) to G&D and W&N CAL (albeit as excludable income under section 118) and therefore as restoring or increasing under section 1367 (b)(2)(B) petitioners' respective tax bases in the outstanding loans each petitioner made to G&D and W&N CAL as follows : Each Petitioner's Tax Bases in Loans To G&D and W&N CAL

G.M. Trading Corporation, Petitioner 106 T.C. No. 13 · 1996

- 3 - under section 118, as a nontaxable capital contribution by the Mexican Government to petitioner or to Procesos.

Epco, Inc. and Subsidiaries, Petitioner T.C. Memo. 1995-499 · 1995

s. - 4 - Petitioner did not report the $35,625 on its 1989 Federal income tax return. In her notice of deficiency, respondent determined that the $35,625 was includable in petitioner's income for 1989 as "contributions in aid of construction" under section 118. At trial and in its briefs, petitioner argued that: (1) The contribution by McArthy (escrowed funds) is not a "contribution in aid of construction" within the meaning of section 118(b), but a nontaxable contribution to the capital of Impe

Thermal Circuits, Inc., Petitioner T.C. Memo. 2026-29 · 2026 · T.C.

Section 118 Thermal argues that the $4.3 million paid by NVT is excludable from income under section 118(a), which provides that “[i]n the case of a corporation, gross income does not include any contribution to the capital of the taxpayer.” The Commissioner argues that the exceptions to section 118(a) found in section 118(b) preclude a capital con

Board of Trade v. Commissioner 106 T.C. 369 · 1996

Petitioner characterizes the transfer fees as contributions to capital and principally relies on section 118 for the proposition that contributions to capital are not included in the gross income of a corporation.

Alternatively, if gain was realized on the exchange of the Mexican debt for the Mexican pesos, petitioner argues that the gain should be regarded as having been realized not by petitioner but by Procesos and that the gain should be treated, under section 118, as a nontaxable contribution of capital by the Mexican Government to Procesos.

Petitioner argues that section 118, which 18 Respondent determined penalties for tax year ending November 30, 2015, as a computational adjustment related to the deficiencies from tax years ending November 30, 2010 through 2012.

138 (2002). Gross income derived from an individual's trade or business may be subject to self-employmenttax even when it is attributable in whole or in part to services rendered in a prior taxable year. Sec. 1.1402(a)-1(c), Income Tax Regs. Section 1402(k) exempts the termination - 7 - [*7] payments ofinsurance salesmen from self-emplo

Section 170(f)(8)(B) provides that a contemporaneous written acknowledgment must include: (i) The amount ofcash and a description (but not value) ofany property other than cash contributed.

Section 170(f)(8)(B) provides that a contemporaneous written acknowledgment must include: (i) The amount ofcash and a description (but not value) ofany property other than cash contributed.

Section 170(f)(8)(B) provides that a contemporaneous written acknowledgment must include: (i) The amount ofcash and a description (but not value) ofany property other than cash contributed.

R Ball for R Ball III by Appt, Petitioner T.C. Memo. 2013-39 · 2013

The taxpayers in Nathel argued that "because section 118 excludes capital contributions from the gross income ofan S - 25 - [*25] corporation in all circumstances, capital contributions to an S corporation are 'permanently excludible' from the gross income ofthe S corporation and are thus tax-exempt income' under section 1.1366-1(a)(2)(viii), Income Tax Regs.".

The taxpayers in Nathel argued that "because section 118 excludes capital contributions from the gross income ofan S - 25 - [*25] corporation in all circumstances, capital contributions to an S corporation are 'permanently excludible' from the gross income ofthe S corporation and are thus tax-exempt income' under section 1.1366-1(a)(2)(viii), Income Tax Regs.".

The taxpayers in Nathel argued that "because section 118 excludes capital contributions from the gross income ofan S - 25 - [*25] corporation in all circumstances, capital contributions to an S corporation are 'permanently excludible' from the gross income ofthe S corporation and are thus tax-exempt income' under section 1.1366-1(a)(2)(viii), Income Tax Regs.".

R Ball Children Trust 9/9/1969, Petitioner T.C. Memo. 2013-39 · 2013

The taxpayers in Nathel argued that "because section 118 excludes capital contributions from the gross income ofan S - 25 - [*25] corporation in all circumstances, capital contributions to an S corporation are 'permanently excludible' from the gross income ofthe S corporation and are thus tax-exempt income' under section 1.1366-1(a)(2)(viii), Income Tax Regs.".

Ethel Ball For A L Ball AS Appt, Petitioner T.C. Memo. 2013-39 · 2013

The taxpayers in Nathel argued that "because section 118 excludes capital contributions from the gross income ofan S - 25 - [*25] corporation in all circumstances, capital contributions to an S corporation are 'permanently excludible' from the gross income ofthe S corporation and are thus tax-exempt income' under section 1.1366-1(a)(2)(viii), Income Tax Regs.".

G.M. Trading Corp. v. Commissioner 106 T.C. 257 · 1996

ealized no gain on the transaction; (2) that the transaction should not be viewed as a taxable exchange because petitioner could not legally own an interest in the U.S.-dollar-denominated debt of the Mexican Government; and (3) that if gain was realized over petitioner’s cost of participating in the transaction, such gain should be regarded, under section 118, as a nontaxable capital contribution by the Mexican Government to petitioner or to Procesos.

Commissioner of Internal Reven v. Brokertec Holdings Inc 967 F.3d 317 · Cir.
Nathel v. Commissioner 131 T.C. 262 · 2008
Sjoroos v. Commissioner 81 T.C. 971 · 1983
James Hotel Co. v. Commissioner 39 T.C. 135 · 1962
Wolfers v. Commissioner 69 T.C. 975 · 1978
Carnation Co. v. Commissioner 71 T.C. 400 · 1978
Trust of Spero v. Commissioner 30 T.C. 845 · 1958
Schairer v. Commissioner 9 T.C. 549 · 1947
Nathel v. Commissioner 615 F.3d 83 · Cir.
At&t, Inc. v. United States 629 F.3d 505 · Cir.
Fox v. Commissioner 82 T.C. 1001 · 1984
Foster v. Commissioner 80 T.C. 34 · 1983
Brandschain v. Commissioner 80 T.C. 746 · 1983
Scott Paper Co. v. Commissioner 74 T.C. 137 · 1980
Insilco Corp. v. Commissioner 73 T.C. 589 · 1979
Siewert v. Commissioner 72 T.C. 326 · 1979
Huber Homes, Inc. v. Commissioner 55 T.C. 598 · 1971
Meyer v. Commissioner 46 T.C. 65 · 1966
Matula v. Commissioner 40 T.C. 914 · 1963
Welsh Homes, Inc. v. Commissioner 32 T.C. 239 · 1959
Beckman Trust v. Commissioner 26 T.C. 1172 · 1956
Kaplan v. Commissioner 21 T.C. 134 · 1953
Coon Run Fuel Co. v. Commissioner 20 T.C. 122 · 1953
Smith v. Commissioner 20 T.C. 663 · 1953
Smith v. Commissioner 17 T.C. 135 · 1951
Stephan v. Commissioner 16 T.C. 1157 · 1951
Freudmann v. Commissioner 10 T.C. 775 · 1948
Hutzler Bro's v. Commissioner 8 T.C. 14 · 1947
Watson v. Commissioner 8 T.C. 569 · 1947
Thorrez v. Commissioner 5 T.C. 60 · 1945
Horne v. Commissioner 5 T.C. 250 · 1945
Adams v. Commissioner 5 T.C. 351 · 1945
McWilliams v. Commissioner 5 T.C. 623 · 1945
Sunvestment Energy Group NY 64 LLC v. National Grid USA Services Co., Inc. 116 F.4th 106 · Cir.
Rodriguez v. United States 852 F.3d 67 · Cir.
Tyngsboro Sports II Solar, LLC v. National Grid USA Service Co., Inc. 88 F.4th 58 · Cir.

New cases, delivered.

Get notified when new Tax Court opinions drop.