THE SPLIT DOLLARMINATOR!
One can hardly miss the high levels of inflation currently affecting our economy. Even for those who do not pay close attention to the news, where inflation could hardly be more covered, the price of nearly everything for...more
In this video Gerry, discusses how a business can use a commercial loan from a bank or a financial institution to help finance it's business obligation in the Loan Regime Split Dollar Method and deduct the interest on the...more
Nowotny on Death and Taxes, episode 17, THE SPLIT DOLLARMINATOR! Using Commercial Lending to “Juice” the Funding of Loan Method Split Dollar Arrangements How a business can use a commercial loan from a bank or a financial...more
This article focuses on how a business can use a commercial loan to help finance a business’ obligation in a Loan Regime Split Dollar Arrangement and deduct the interest payments for its tax purposes, without running afoul of...more
The Internal Revenue Service (IRS) recently issued Notice 2020-32 (Notice), which discusses the deductibility of expenses that are funded by a Paycheck Protection Plan (PPP) loan and the subsequent loan forgiveness. Section...more
On September 6, 2019, the Internal Revenue Service (IRS) announced the new “Relief Procedures for Certain Former Citizens” (IRS Relief Procedures) who relinquished their United States (U.S.) Citizenship after March 18, 2010....more
Proposed Section 382(h) regulations released this week (the Proposed Regulations) potentially would increase the scope of a corporation’s income – namely, cancellation of debt income (COD Income) - recognized after an...more
Proposed regulations under Section 163(j) governing business interest deduction limitations confirm prior guidance and expand the scope of its application in some important respects. On November 26, 2018, the Treasury and...more
Released on November 30, 2018, the foreign tax credit proposed regulations provide a comprehensive new framework for calculating the foreign tax credit in light of several changes made by the Tax Cuts and Jobs Act (TCJA or...more
On Nov. 26, 2018, the Department of the Treasury and the Internal Revenue Service issued proposed regulations under Section 163(j) of the Internal Revenue Code regarding the limitation on the deduction for business interest...more
The Tax Cuts and Jobs Act of 2017 (“TCJA”) made substantial changes to the Tax Code of 1986 by reducing tax rates and “simplifying” tax compliance for many by significantly increasing the standard deduction and eliminating...more
New tax legislation was signed into law on December 22, 2017 (the Act). The Act lowers the corporate rate from a top graduated rate of 35 percent to a flat rate of 21 percent. Under the Act individuals and certain...more
• As noted in Part 1 of this series, new H.R. 1, informally known as the Tax Cuts and Jobs Act (Tax Act), has been the most important change to the U.S. tax code in a generation. • In Part 2, this client alert continues to...more
The IRS announces certain key aspects of the interest deduction limitation that will be addressed in upcoming Treasury regulations. Key Points: ..The 30% Cap (as defined below) will apply at the consolidated group...more
Employers that pay wages and other forms of compensation to their employees must comply with federal tax return filing and payment/deposit requirement. Employers that receive services from non-employee contractors and which...more
If an individual or business owes federal taxes and does not have the current ability to pay these taxes, the IRS can consider placing the account into “currently not collectible” (CNC) status. If placed in CNC status, a...more
How much were the late King of Pop’s name and image worth when he died? His estate put the figure at $2,105 but the IRS believes the value is at least $434 million. That’s a huge discrepancy and with penalties and interest...more
The South Carolina General Assembly approved a law in 2015 allowing the South Carolina Department of Revenue to offer an amnesty program to taxpayers in the state who have not filed tax returns and/or owe state taxes....more
Tax Court Denies Commissioner’s Motion to Compel After Predictive Coding Used to Identify Responsive Documents - On July 13, 2016, Judge Ronald Buch of the Tax Court denied the Commissioner’s motion to compel Dynamo...more
On October 13, 2016, Treasury and the IRS issued important new final and temporary regulations (the “Regulations”) under section 385 of the Internal Revenue Code addressing the treatment of intercompany debt for U.S. federal...more
An act passed by Congress last year makes changes to IRS Form 1098 (Mortgage Interest Statement) starting in tax year 2016 (reported commencing in calendar year 2017). Internal Revenue Code Section 6050H(b)(2)(D) requires...more
I Just Received Drafts of Construction Loan Documents from My Lender, Now What? I have heard the following statement many, many times over the course of my career: “Do I really need to hire an attorney to close a simple...more