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New partnership audit rules can apply to partnerships, LLCs with only a few partners, members

Effective in 2018, changes in partnership audit rules may apply the following (and other) consequences to partnerships (including LLCs taxed as such)...more

Developments in FICA and self-employment tax affect partners and S corporations

I was recently honored to serve as a guest columnist in the June 2017 “Shop Talk” column in WG&L’s Journal of Taxation. The article, “Developments in FICA and Self-Employment Tax Affect Partners and S Corporations,” tied...more

[Webinar] Leveraging to Attain Basis Step-Up; Income Tax Benefits of Losing an FLP Case - July 11th, 12:00pm CT

Please join us for a webinar based on Steve Gorin's Second Quarter 2017 newsletter, Gorin's Business Succession Solutions. In this webinar the presenter will discuss that one can use debt to allow property to obtain a...more

IRS gets upper hand in S corporation compensation audits

Any compensation the owner receives is subject to FICA tax, which imposes an equivalent burden. And the IRS frequently attacks owners who receive cash distributions from an S corporation, arguing that the distributions were...more

Tax court finds self-employment tax for active LLC member

Self-employment (SE) tax is one of the driving forces when a tax advisor recommends what type of entity to use for one’s business. My previous post, “Tax court finds no self-employment tax for passive LLC member,” described...more

Using an S corporation to avoid self-employment tax

Our last post discussed self-employment (SE) tax and taxpayers’ efforts to avoid that tax when using an entity taxed as a partnership to conduct business. It concluded that a limited partnership that conducted business...more

[Webinar] Landmark Tax Court Self-Employment Tax Decision; Post-Mortem Planning for Business Owners; Reimbursing Deemed Owner of...

This free webinar will orally discuss my 1st Quarter 2017 newsletter, including: - For the first time ever, the Tax Court ruled that a member of a limited liability company was not subject to self-employment tax. We...more

Tax court finds no self-employment tax for passive LLC member

Self-employment (SE) tax is one of the driving forces when a tax advisor recommends what type of entity to use for one’s business. This article describes SE tax, lists some common exceptions, explains the suggestion that an...more

Lawyers: Give your clients a business entity checkup

As we prepare for perhaps another round of major tax law changes, you might want to consider the status of your clients’ legal postures. Making a client’s business structure more nimble or setting the stage to obtain outside...more

Highlights from the 2017 Heckerling Institute on Estate Planning

Each January, the University of Miami hosts the Heckerling Institute on Estate Planning, the country’s largest estate planning seminar. During the seminar, reporters for the American Bar Association’s Real Property Trust &...more

CPAs: Top 10 list for fiduciary income tax returns and planning

As we near tax season, below are some tips for CPAs when planning and preparing tax returns for trusts, along with a link to an upcoming webinar on this very topic. ...more

Tax basis: The key to reducing gain on sale or deducting asset purchases

This article discusses key ideas used in reducing or eliminating gain subject to tax when you sell an interest in your business or when your business sells part or all its assets. These ideas can also possibly help those who...more

[Webinar] Fiduciary Income Tax Refresher and Update - February 7th, 12:00pm CT

In the webinar the presenters will discuss tax-savings tools that can be used between now and March 6 when preparing 2016 returns. The presenters will provide a top-ten list of planning tips to help attendees save income tax...more

[Webinar] Self-Employment Tax and LLCs; New Partnership Audit Rules; Selected Issues from Heckerling - Jan. 24th, 12:00pm CT

In the webinar we will analyze a recent IRS memo delineating between when it will and will not respect efforts to make a member of an LLC subject to self-employment tax. We will become sensitized to how upcoming partnership...more

[Webinar] Business Planning in Light of Proposed Regulations under Code § 2704 - October 27th, 12:00p.m. CT

In this webinar, Steve Gorin, the author of his quarterly newsletter, will discuss the proposed regulations under IRC § 2704 that would increase the valuation of business entities in many cases. Attendees will learn when the...more

Upcoming CLE examines ways to avoid tax traps in life insurance

Beware that an employer-owned life insurance contract might not qualify for the usual exclusion from regular income tax. An “employer-owned life insurance contract” (a term that applied to much more than one would think) does...more

9/28/2016  /  Income Taxes , Life Insurance

Proposed changes to Section 2704 could spur tax increase for owners of closely held businesses

Controversial proposed regulations issued by the Treasury and the IRS on August 4, 2016, would change rules for valuing interests in business entities of which a person or a family owns at least one-half. The regulations...more

[Webinar] Life Insurance to Fund Buyouts or Loss of a Key Person: Practical Ways to Avoid Tax Traps and Other Pitfalls - September...

Life insurance can help a business that loses an owner or other key person. Although life insurance death benefits can be tax-free, part or all of the benefits are taxable if not done the right way. Please join Steven B....more

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