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

Applicable Federal Rates – February 2015

see charts below…more
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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

Joint Obligors – Who Gets the Interest Deduction

In a recent Chief Council Advice, the IRS summarizes and reaffirms various principles that can be applied to determine who gets an interest deduction for payments made on a home mortgage when there is more than obligor under the…more
| Finance & Banking, Real Estate - Residential, Taxation

Applicable Federal Rates – January 2015

Please see charts below…more
| Taxation

Highlights of Final Regulations for Reporting of Specified Foreign Financial Assets

The Treasury Department has issued final regulations relating to reporting of specified foreign financial assets on Form 8938. The highlights include..…more
| Finance & Banking, International Law & Trade, Taxation

Protector Power To Amend Trust Upheld, But Litigants Also Raise An Interesting Accounting Issue [Florida] – Part Il

Earlier this week I wrote about a recent Florida case that upheld the ability of a trust “protector” to amend the provisions of a trust. In that posting, I alluded to an interesting trust accounting issue…more
| Taxation, Wills, Trusts, & Estate Planning

Protector Power To Amend Trust Upheld, But Litigants Also Raise An Interesting Accounting Issue [Florida] – Part I

A recent Florida appellate court decision upholds the ability of a trust “protector” to amend the provisions of a trust. Florida Statutes Section 736.0808(e) provides that “[t]he terms of a trust may confer on a trustee…more
| Taxation, Wills, Trusts, & Estate Planning

Employer Cash Payments To Reimburse Employees For Health Insurance Costs – No!

Many employers offer or provide cash to employees to reimburse them for the cost of purchasing an individual health insurance policy. Others offer employees with high claims risk a choice between enrolling in the company’s…more
| Labor & Employment Law, Health, Taxation

Overpayment and Underpayment Rates-1st Quarter 2015

Please see chart below…more
| Commercial Law & Contracts, Taxation

2014 Extenders Clear the House

For many years now, Congress has contributed to tax uncertainty by extending certain favorable tax provisions on a year by year basis. Thus, for example, in 2014 these extenders have expired. Neither the IRS, who has to prepare…more
| Commercial Law & Contracts, Elections & Politics, Finance & Banking, Real Estate - Residential, Taxation
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Areas of Practice
  • Business Organizations
  • Taxation
  • Wills, Trusts, & Estate Planning
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