Ross Cohen

Ross Cohen

Baker Donelson

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Latest Publications


Spotlight on Alabama: Department of Revenue Announces 2016 Tax Amnesty Program

The Alabama Department of Revenue (DOR) has announced the conditions, requirements and limitations of its tax delinquency amnesty program for 2016 (the Amnesty Program), pursuant to the Alabama Tax Delinquency Amnesty Act of...more

5/12/2016 - Business Taxes Department of Revenue Income Taxes State Taxes Tax Amnesty

Tax Court Affirms Use of Intergenerational Split-Dollar Arrangements

The Tax Court, in its decision earlier this month in Estate of Morrissette, examined intergenerational split-dollar arrangements between a mother's revocable trust and three irrevocable dynasty trusts, one established for...more

4/28/2016 - Business Succession Dynasty Trust Revocable Trusts Split Dollar Tax Court Wealth Management

New Opportunity for 'C' Corporations to Convert to 'S' Corporations Under Recent Tax Law

Since 1986, when the General Utilities doctrine (permitting corporate liquidations of regular or 'C' corporations to be tax-free to the corporation) was repealed, a barrier existed for 'C' corporations to convert to...more

2/16/2016 - C-Corporation Corporate Taxes Protecting Americans from Tax Hikes (PATH) Act S-Corporation Tax Liability

Alabama Tax Tribunal Rules Certain Freight Charges are Not Subject to Sales Tax

In Mike Kilgo & Associates, Inc. v. State of Alabama Department of Revenue, the Alabama Tax Tribunal recently ruled that freight and shipping charges separately stated from other charges on a seller's invoice are not subject...more

2/9/2016 - Common Carriers Department of Revenue Sales Tax Service Charges Shipping

Business Succession Planning in the Current Tax Environment

Business succession planning in the current tax environment may require an adjustment in thinking from traditional planning. Traditional planning usually attempts to transfer ownership of the business to the next owner (often...more

7/22/2015 - Business Succession Capital Gains Estate Tax Estate-Tax Exemption Fair Market Value Gift Tax Inheritance Tax Rates

ESOPs: The Tax Law Provides a Buyer for Your Business

As baby boomer business owners begin to retire, many will want to monetize the value they have created in their businesses. An employee stock ownership plan (ESOP) is one alternative. The ESOP alternative, authorized by the...more

9/29/2014 - 401k C-Corporation ESOP Internal Revenue Code (IRC) Retirement Plan S-Corporation

Goodwill Owned by a Shareholder Can Provide Tax Planning Opportunities

A recent U.S. Tax Court case reminds us that the personal goodwill owned by the principal shareholder/employee can provide significant tax planning opportunities. Generally, the sale of assets by a "regular" corporation...more

7/17/2014 - Goodwill Liquidation Sale of Assets Shareholders Tax Court Tax Planning Trucking Industry

Spotlight on Alabama: Legislature Passes Two Pro-Business Tax Acts

Earlier this month the Alabama Legislature passed two pro-business tax acts. Both acts received the support of various business groups in the state. The first has already been signed into law by Governor Bentley, and we...more

3/14/2014 - Business Taxes Corporate Taxes Tax Reform

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