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Related-Party Provisions Prevent Deduction by S Corp Shareholders - Tax Update Volume 2017, Issue 4

Many routine transactions occur between related parties, including the payment or accrual of interest on indebtedness, license fees, salary or benefits to employees and/or shareholders, and trade invoices. The Tax Court...more

Duty of Consistency Doctrine - Effective Sword for the IRS, but Not Likely a Shield for Taxpayers - Tax Update Volume 2016, Issue...

Two recent cases illustrate the IRS’ ability to successfully argue that taxpayers should not benefit from their own mistakes if they result in less tax being paid. Two recent cases highlight the most current view of the...more

Deductibility of Transaction Costs for a Target Company: No Safe Harbor in Deemed Asset Deals

On June 10, 2016, the Internal Revenue Service released a Chief Counsel Memorandum dated July 8, 2015, addressing the issue of whether a target S-corporation, which participated in a transaction in which the parties made a...more

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