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

Applicable Federal Rates - September 2016

Please see charts below for more information. …more
| Taxation

Practice Aid – A Redlined Version of the Proposed Section 2701 and 2704 Regulations

These proposed regulations are difficult enough in substance to deal with, without having to piece together the changes that they make to the existing regulations. Maybe there is a redlined version out there already, but I could…more
| Business Organizations, Taxation, Wills, Trusts, & Estate Planning

No Obligation to File Inaccurate Return to Avoid Failure to File Penalty

A partnership was a partner in a Cayman Islands partnership - that investment made up most of its assets. The Cayman Islands partnership did not file a Form 1065 income tax return and did not give a Form K-1 to the taxpayer…more
| Business Organizations, Commercial Law & Contracts, International Law & Trade, Taxation

Updated ITIN Procedures

Foreign individuals who are ineligible to obtain a social security number but who require a U.S. taxpayer identification number can apply for a an Individual Taxpayer Identification Number (ITIN) using Form W-7. The process is…more
| International Law & Trade, Taxation

Some Food for Thought - Code Section 2704 Proposed Regulations

As the proposed regulations are digested by practitioners, here is some food for thought: a. Will GRATs be underwater from the start - that is, nondiscounted values for the funding transactions, and discounted values for…more
| Commercial Law & Contracts, Taxation, Wills, Trusts, & Estate Planning

IRS Issues Long-Awaiting Section 2704 Proposed Regulations

In case you haven’t heard, these proposed regulations were issued on August 2. The particular focus is to substantially reduce valuation discounts for transfer tax purposes on minority interests, nonvoting, and limited control…more
| Business Organizations, Taxation, Wills, Trusts, & Estate Planning

Executrix Held Liable Under Federal Claims Statute For Actions Taken Prior to Appointment as Executrix

A decedent died while owing over $340,000 in unpaid federal income tax liabilities. His estate was insolvent. The assets of his estate consisted almost entirely of a 100% interest in one corporation and 50% of another…more
| Commercial Law & Contracts, Labor & Employment Law, Securities Law, Taxation, Wills, Trusts, & Estate Planning

IRS Wins Debt vs. Equity Case

A frequent area of dispute between taxpayers and the IRS is whether an indebtedness obligation should be treated as debt, or an equity investment, for income tax purposes. Taxpayers often seek debt treatment to obtain interest…more
| Commercial Law & Contracts, International Law & Trade, Taxation

Treasury Removes a Reporting Trap for Section 83(b) Elections

Taxpayers who receive property as payment for performing services are generally taxable on the value of the property received in the year of receipt. Section 83 may allow such taxation to be deferred when the property received…more
| Commercial Law & Contracts, Labor & Employment Law, Securities Law, Taxation

Applicable Federal Rates - August 2016

Please see charts below for more information…more
| Taxation

Safe Harbor Acquisition of Control for Spin-Offs

Code Section 355, and related Code provisions, when applicable, will allow a corporation to spin-off or split-off a subsidiary corporation to its shareholders without triggering gain to the corporation or its stockholders. One…more
| Business Organizations, Commercial Law & Contracts, Mergers & Acquisitions, Taxation

State Court Retroactive Change to IRA Beneficiary Not Given Tax Effect by IRS

A decedent had 2 IRAs. The death beneficiaries of the IRAs were trusts that qualified as "look through" trusts, such that the payout period for the IRAs after the decedent died could be computed using the life expectancy of the…more
| Finance & Banking, Labor & Employment Law, Taxation, Wills, Trusts, & Estate Planning

Napkin Theory Saves the Day [Florida]

Renee established and funded a revocable trust, with charitable residuary beneficiaries at her death. The trust was revocable, but it did not provide a method for revocation. Four years later, Renee prepared a will that…more
| Wills, Trusts, & Estate Planning

Anatomy of a Busted Tax Rescue Transaction

For many years, there were companies out there that marketed a service to tax professionals to help their corporate clients with large tax liabilities. I remember receiving solicitations to think of them if I came across…more
| Commercial Law & Contracts, Taxation

Withholding Agents–Obligation to Withhold On Payments to Foreign Persons When Source of Payment Uncertain

In recent guidance to auditors, the IRS discusses what happens when a payor withholding agent pays items to a foreign payee when the withholding agent is uncertain whether the payment is U.S. source…more
| International Law & Trade, Taxation
Showing 1-15 of 552 Results
|
View per page
Page: of 37
Contact

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

  • 561-998-7847

Areas of Practice
  • Business Organizations
  • Taxation
  • Wills, Trusts, & Estate Planning
Badges
Verified
This profile may constitute attorney advertising. Prior results do not guarantee a similar outcome. Any correspondence with this profile holder does not constitute a client/attorney relationship. Neither the content on this profile nor transmissions between you and the profile holder through this profile are intended to provide legal or other advice or to create an attorney-client relationship.

"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*

*By using the service, you signify your acceptance of JD Supra's Privacy Policy.

Already signed up? Log in here

*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.
×