Episode 93: Maximiliano Concha Rodríguez | PAGBAM Schwencke, Chile
GILTI Conscience Podcast | Inside the IRS: A Conversation With Former Agency Officials
Podcast - La Prima por Fusión
GILTI Conscience Podcast | Spotlight Series: Utilizing Tax Knowledge for the Greater Good
10 Things Lawyers Should Know About BVI Transactions
Tax Planning Under a Biden Presidency
Podcast: Tax Reform and Its Impact on Exempt Organizations, One Year In
Lawyers on Tap: Tap Tips for Entity Formation and Taxation
Tax Provisions in Business Acquisition Agreements
Check out our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of July 22, 2024 – July 26, 2024....more
I seem to have been on a writing sabbatical for the last year. Over the course of the year, I have discovered a few new planning ideas to share going forward. From previous articles you already know that I grew up in the...more
While marijuana advocates celebrate the potential rescheduling of marijuana from Schedule I to Schedule III, the taxman has made clear that marijuana remains a Schedule I substance subject to Section 280E of the Internal...more
Check out our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of June 10, 2024 – June 14, 2024....more
Check out our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of April 29, 2024 – May 3, 2024. ...more
Check out our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of March 11, 2024 – March 15, 2024. ...more
This fourth installment of my multi-part series on Subchapter S is focused on suspended losses of an S corporation. While the rules seem straightforward, their application can be tricky, especially given legislative changes...more
On February 21, 2024, the Internal Revenue Service (IRS) announced plans to commence a focused audit effort targeting private aircraft usage by dozens of large corporations, large partnerships and high-income individual...more
Check out our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of February 12, 2024 – February 16, 2024. ...more
Check out our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of January 22, 2024 – January 26, 2024....more
Check out our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of January 15, 2024 – January 19, 2024. ...more
Check out our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of November 6, 2023 – November 10, 2023...more
Check out our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of September 4, 2023 – September 8, 2023. ...more
Check out our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of May 8, 2023 – May 12, 2023...more
Many senior housing properties are owned by limited liability companies or other entities that are taxed as partnerships for federal income tax purposes. The March 15th deadline for filing federal partnership tax returns is...more
Presented below is our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of January 17, 2023 – January 20, 2023...more
Short Summary: Petitioner Susan Kechijian sought the Tax Court’s review, under section 6015(e), of the denial by the IRS of her request for innocent spouse relief from joint and several liability for a federal income tax...more
On December 8, Treasury issued final regulations (the “Final Regulations”) updating the existing centralized partnership audit regime. These regulations largely adopt the provisions of regulations that were previously...more
Presented below is our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of September 26, 2022 – September 30, 2022....more
Tax Litigation: The Week of August 1st, 2022, through August 5th, 2022 Whistleblower 769-16W v. Comm’r, 159 T.C. No. 2 | August 4, 2022 | Toro, J. | Dkt. No. 769-16W ...more
Tax Litigation: The Week of July 11th, 2022, through July 15th, 2022 Estate of DeMuth, v. Comm’r, T.C. Memo. 2022-72 | July 12, 2022 | Jones, J. | Dkt. No. 18724-19 Whistleblower 972-17W v. Comm’r, 159 T.C. No. 1 | July 13,...more
Tax Litigation: The Week of March 7, 2022, through March 11, 2022 Hacker v. Comm’r, T.C. Memo. 2022-16 | March 8, 2022 | Paris, J. | Dkt. No. 3870-12 Cosio v. Comm’r, T.C. Memo. 2022-18 | March 9, 2022 | Weiler, J. | Dkt....more
Partnership Formation - The formation of a partnership is generally a nonrecognition transaction for both the contributing partner and the newly-created partnership. Thus, as a general rule, no gain is recognized by a...more
In a previous post, we highlighted guidance released by the IRS on the topic of “relevance” and some of the implications it had in the pre-immigration planning context. More specifically, the guidance addressed issues...more
Hobby Loss or Business Loss Tax Deduction - It’s not every day that a case comes through the Tax Court centered on the taxation of miniature donkey breeding. But the recent case of Huff v. Commissioner was focused on just...more