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

3 Strikes Against the IRS in Attempting to Impose Fiduciary and Beneficiary Liability for Estate Taxes

During her lifetime, Anna Smith established the Anna Smith Family Trust, a revocable trust administered for her benefit. Initially, Anna was initially a co-trustee with two of her children, but eventually became sole trustee. A…more
| Taxation, Wills, Trusts, & Estate Planning

Burden of Proof Issues in Gift Tax Matter

A recent case illustrates 3 important burden of proof issues. The general facts of the case involved a merger of a company owned by parents with a company owned by children. The gift tax issue involved the relative value of…more
| Business Organizations, Taxation, Wills, Trusts, & Estate Planning

Gift Tax Statute of Limitations if Prior Gifts Omitted from Return

The IRS only has three years after a Form 709 is filed to assess gift taxes on a gift, so long as the gift is adequately disclosed on the return. If a gift is not disclosed, the statute of limitations does not begin to run on…more
| Civil Procedure, Taxation

IRS on the Hunt for Bitcoin Users

Bitcoin is the most popular of the virtual currencies. In Notice 2014-21, the IRS advised that such currencies are not money, but property, for tax purposes. Two implications of this are that persons who use Bitcoins to purchase…more
| Finance & Banking, Science, Computers, & Technology, Taxation

Of Course You Should Trust the IRS with Your Financial Information

The income tax provides justification for massive government intrusion into the financial privacy of its taxpayers. Its information gathering capacity and demands run wide and deep, and expand with almost every piece of enacted…more
| Finance & Banking, Privacy, Taxation

Corporate Tax Reform on the Front Burner?

There is a clue out there that President-elect Trump may first want to tackle corporate tax reform, before moving on to individual tax reform (both of which involve rate reductions). This is because Stephen Moore, a Heritage…more
| Commercial Law & Contracts, Elections & Politics, Taxation

Applicable Federal Rates - December 2016

Please see charts below for more information…more
| Taxation

New Regulations Issued Regarding CFCs and Investment in U.S. Property

Income earned abroad by U.S. controlled foreign corporations can often qualify for deferral of U.S. income tax. If the foreign corporation is a controlled foreign corporation (CFC), its U.S. shareholders may be taxable on such…more
| Commercial Law & Contracts, International Law & Trade, Real Estate - Commercial, Real Estate - Residential, Taxation

What Kind of Tax Changes Can We Expect From Trump's Presidency?

The tears have not yet dried for some, and the celebrating is not yet over for others, but let's turn our attention to taxes. With a Republican Congress and a Republican president, some measure of tax relief is a given. What can…more
| Commercial Law & Contracts, Elections & Politics, Health, Taxation, Wills, Trusts, & Estate Planning

$100 Million FBAR Penalty - Ouch

Taxpayers who fail to file Reports of Foreign Bank and Financial Accounts (FBARs) disclosing their non-U.S. accounts can suffer a 50% penalty on the balance of the unreported accounts. In one of the largest penalties I have…more
| Commercial Law & Contracts, Finance & Banking, International Law & Trade, Taxation

Exceptions to Limited Liability for LLC Members [Florida]

Fla.Stats. §605.0304(1) provides for the limited liability of LLC members - it provides: "A debt, obligation, or other liability of a limited liability company is solely the debt, obligation, or other liability of the company. A…more
| Business Organizations, Commercial Law & Contracts, Taxation

2017 Inflation Adjustments

Rev. Proc. 2016-55 has provided adjusted figures for 2017 for tax items subject to inflation adjustments…more
| Taxation, Wills, Trusts, & Estate Planning

Overview of New Section 385 Regulations

The IRS has issued final and temporary regulations under Code Section 385. These provisions, intended to limit earnings stripping, will enhance the IRS' ability to characterize related party ownership arrangements, purportedly…more
| Taxation

Section 385 Regulations Issued - Not as Harsh as The Proposed Regulations

Earlier this year, the IRS issued proposed regulations on the conversion of purported related party debt to equity. The IRS has now issued temporary and final regulations on the subject…more
| Commercial Law & Contracts, Taxation

Executor Loses Out on Fees Due to Section 6166 Lien

A personal representative/executor for an estate granted a special estate tax lien under Code §6324A to the U.S. as part of a Section 6166 election to defer payment of federal estate tax. At the time, the executor had been paid…more
| Civil Procedure, Taxation, Wills, Trusts, & Estate Planning
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  • Wills, Trusts, & Estate Planning
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