Non-Taxable Income

News & Analysis as of

IRS Changes Position on Non-Taxable IRA Rollover Contributions

The U.S. Tax Court recently decided that the one-per-year IRA rollover limitation in 26 U.S.C. § 408(d)(3)(B) applies in the aggregate to all of the taxpayer’s IRA accounts rather than separately to each of a taxpayer’s IRA...more

Sutherland SALT Shaker: August 2013 Digest

In this issue: - No Expressions of Goodwill from Arizona Department of Revenue - California Court of Appeal: ITFA Doesn’t Make the CUT - Round We Go: Indiana Denies Taxpayer’s Intercompany “Residual...more

For Private Equity Investors, Section 1202 May Be Worth Another Look

Included in the American Taxpayer Relief Act of 2012 (ATRA) are provisions that extended some of the more significant benefits of Internal Revenue Code Section 1202, the Code provision that permits eligible noncorporate...more

Tax Topics: Restrictive Covenants — The Final Chapter (For Now)— Part I

This article discusses proposed legislation dealing with the taxation of restrictive covenants. Due to its length, it is divided into two parts. Part I addresses the history, basic inclusion rules, tax treatment to the...more

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