Charles (Chuck) Rubin – Gutter Chaves Josepher Rubin Forman Fleisher P.A.

2101 NW Corporate Blvd. Suite 107
Boca Raton, Florida 33431, United States

  • 561-998-7847

Hollow Taxpayer Victory When IRS Unlawfully Discloses Taxpayer Information to Japan

By law, the U.S. is not permitted to disclose false return information, even if the release of false return information is authorized by law and treaty. Code Section 7431 imposes liability on the U.S. if it discloses return…more
| Civil Remedies, International Law & Trade, Taxation

Applicable Federal Rates – March 2015

Please see charts below…more
| Taxation

Getting to Appeals In an Estate or Gift Tax Audit with Pending Information Requests

Ain’t gonna happen! So says the IRS in guidance released by the IRS, at least in most circumstances. In a memo to IRS estate and gift tax examination employees, the IRS advises..…more
| Taxation, Wills, Trusts, & Estate Planning

Does a Tenant Cohabitate?

Marital agreements and trust agreements often employ the term “cohabitate” or “cohabitation.” Typically, these agreements provide for the end of trust distributions, alimony, occupancy of property, or other benefits, when the…more
| Family Law, Taxation, Wills, Trusts, & Estate Planning

CARE Act Battleground

The Republicans to date have not put forth an alternative to Obamacare. To fill this vacuum, Senator Richard Burr has put forth an alternative to Obamacare – the Patient Choice, Affordability, Responsibility, and Empowerment Act…more
| Health, Taxation

At What Price Certainty?

The complexity of federal tax law is well known. Oftentimes, questions come up that are not answered clearly in the law. To help taxpayers obtain answers they can rely on, the IRS will issue private letter rulings as to the IRS’…more
| Taxation

IRS Error in Extending Statute of Limitations for Wrong Year is Disregarded

When a taxpayer files a federal tax return, the IRS generally has a 3 year statute of limitations period to assess additional tax beyond that reported on the return. If the tax year is audited, the auditor may ask the taxpayer…more
| Taxation

The Law is an Ass

The law is an ass, or so says Charles Dickens. After reading the IRS’ latest missive on sales of marijuana, I think I agree. The tension between federal and state law on the sale of marijuana carries over to federal income…more
| Conflict of Laws, Taxation

Applicable Federal Rates – February 2015

see charts below…more
|

No Private Letter Rulings in These Estate Planning Areas

Taxpayers who have questions about the applicability of tax law can submit a Private Letter Ruling request to the IRS. If the IRS rules, then the taxpayer can rely on the ruling as to how the law applies to their situation…more
| International Law & Trade, Real Estate - Residential, Taxation, Wills, Trusts, & Estate Planning

National Taxpayer Advocate 2014 Annual Report to Congress

The National Taxpayer Advocate has issued her annual report. This report highlights areas of tax law and IRS administration that are not in compliance with law or that require improvement. While Congress and the IRS will review…more
| Taxation

IRS Hammers Offshore Lending and Underwriting Structure

In a recent Chief Counsel Advice, in an extended analysis the IRS determined that an offshore partnership with a U.S. manager that was engaged in the finance transactions was determined to be engaged in a U.S. trade or business…more
| Commercial Law & Contracts, Finance & Banking, International Law & Trade, Taxation

House of Representatives Adopts Dynamic Scoring

Proposed legislation is subject to an analysis that estimates its effect on the budget deficit. Under static scoring, the legislation itself is not assumed to change the economy. Thus, for example, if a 1% drop in tax rates is…more
| Elections & Politics, Taxation

Another Circuit Finds Federal Substance over Form Doctrine Inapplicable in Transferee Liability Case

For a transferee of assets to be held liable under Section 6901 for the income taxes of the transferor, two elements must be met. First, the party must be a transferee under Section 6901. This is a federal law question, and…more
| Commercial Law & Contracts, Taxation

PLR Confirms Section 332 Coverage of Check-The-Box Election of Wholly-Owned Subsidiary

When an existing corporation makes a check-the-box election to be a disregarded entity, this is treated as a corporate liquidation. This can result in gains to the electing entity under Code Section 337 pursuant to a deemed sale…more
| Commercial Law & Contracts, Taxation
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Areas of Practice
  • Business Organizations
  • Taxation
  • Wills, Trusts, & Estate Planning
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