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

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

Applicable Federal Rates – July 2016

Please see charts below for more information…more
| Taxation

Whose Fraud Extends the Statute of Limitations on Assessment?

The IRS generally has 3 years to assess additional tax after a return is filed. Code Section 6501(a).However, an important exception is Code Section 6501(c)(1). Under that provision, if there is fraud in regard to the…more
| Civil Procedure, Taxation

IRS Tax Liens and Discretionary Trust Interests - Part 2

In April, I wrote how a U.S. District Court held that a beneficiary’s discretionary interest could be liened by the IRS for tax liabilities of the beneficiary. The interest was “halfway” between a purely discretionary interest…more
| Civil Remedies, Taxation, Wills, Trusts, & Estate Planning

Federal Tax Overpayment & Underpayment Interest Rates–3rd Quarter 2016

Please see Charts below for more information…more
| Commercial Law & Contracts, Taxation

Taxpayer Required to Pay Tax Twice on the Same Income - Tax Court Unsympathetic

A taxpayer in the medical supply business received payments from Cigna before 2005. He reported those items in income and paid federal income tax on them. A dispute later arose and the taxpayer returned payments to Cigna…more
| Labor & Employment Law, Taxation

What Happens to Jointly Owned Property When One of the Owners Owes the IRS

Leonard and Joyce owned 50% of a commercial property. Their son, Derek, owned the other 50%. The IRS liened the property due to amounts owed by Leonard and Joyce to the IRS for unpaid taxes. The IRS sought to foreclose its tax…more
| Real Estate - Commercial, Taxation

Make Sure the Corporation is in Good Standing Before Filing a Tax Court Petition

Many states will involuntarily or administratively dissolve a corporation for not paying or filing annual reports, fees, or tax returns. The ability of a dissolved corporation to engage in activities after dissolution depends on…more
| Commercial Law & Contracts, Taxation

2014 Statistics of Income

The IRS regularly releases information garnered from tax filings. For those with an interest in this sort of information, based on individual income tax returns for 2014..…more
| Labor & Employment Law, Taxation
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Areas of Practice
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  • Taxation
  • Wills, Trusts, & Estate Planning
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