News & Analysis as of

Liquidation Tax Court

Rivkin Radler LLP

Shareholder-Transferee Liability for a Corporation’s Income Tax

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Would you be surprised to learn that most shareholders of closely held corporations, and especially those with minority or merely passive interests, believe they cannot be held responsible for the tax obligations of their...more

Rivkin Radler LLP

Indirectly Held Profits Interests and Rev. Proc. 93-27

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At war with Russia in eastern Europe, a nascent competing world order, mass shootings and bank failures at home, questionable audit practices by the Big 4 . . . everywhere, debt ceilings and the risk of default, inflation,...more

Rivkin Radler LLP

Capital vs Ordinary Loss When An Investment Goes South

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Capital Loss- If the amount realized by a taxpayer upon the sale of a partnership interest to a third party is insufficient to restore to the taxpayer their adjusted basis for the interest – i.e., their unrecovered...more

Lowndes

Abandonment Losses Back on the Table!

Lowndes on

Several years ago, many taxpayers faced with underwater partnerships would abandon their partnership interests, thereby triggering an ordinary loss. This ordinary loss was often preferred over the capital loss that would be...more

Baker Donelson

Goodwill Owned by a Shareholder Can Provide Tax Planning Opportunities

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A recent U.S. Tax Court case reminds us that the personal goodwill owned by the principal shareholder/employee can provide significant tax planning opportunities. Generally, the sale of assets by a "regular" corporation...more

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