Gary Michel

Gary Michel

Ervin Cohen & Jessup LLP

Contact  |  View Bio  |  RSS

Latest Publications

Share:

Converting a Profits (or Carried) Interest Into a Capital Interest Tax-Free, Even if it is a Marketable Security

In CCA 201517006 (dated 10/9/14 and released 4/24/15), the general partner of a publicly traded partnership (PTP) had, in addition to its capital interest, a profits interest in the PTP called “incentive distribution rights”...more

7/16/2015 - Corporate Taxes General Partnerships IRS Limited Partnerships Partnership Interests Profits Interests Publicly-Traded Companies Right of Distribution Securities

Be Sure to File a Protective Claim for FICA Taxes

The Supreme Court has agreed to review the Sixth Circuit Court of Appeals decision in United States v. Quality Stores which held that severance payments to involuntarily terminated employees were supplemental unemployment...more

2/19/2014 - FICA Taxes Income Taxes Quality Stores SCOTUS Severance Pay Termination

Hidden Gem in New Tax Law – S Corporation Built-In Gain Recognition Period Reduced to 5 Years

More details of the American Taxpayer Relief Act of 2012, which President Obama signed into law yesterday, January 2, 2013, will be release shortly. But in the meantime, we know from the text of the legislation (HR 8) that...more

1/3/2013 - American Taxpayer Relief Act Corporate Taxes Fiscal Cliff S-Corporation

Locking in 2012’s Long-Term Capital Gains Tax Rate

Did you sell your business in 2012 and defer any of the purchase price? This could be the case if you financed part of the purchase price (i.e., you took back the buyer’s note), or there was an earnout whereby you receive...more

12/5/2012 - Capital Gains Installment Agreements Tax Rates

4 Results
|
View per page
Page: of 1

"My best business intelligence, in one easy email…"

Your first step to building a free, personalized, morning email brief covering pertinent authors and topics on JD Supra:

Sign up to create your digest using LinkedIn*

*With LinkedIn, you don't need to create a separate login to manage your free JD Supra account, and we can make suggestions based on your needs and interests. We will not post anything on LinkedIn in your name. Or, sign up using your email address.
×