Day 17 of One Month to More Effective Continuous Improvement-Financial Health Monitoring
This Year's AmLaw 100: "Fundamental Recovery" for Some
It's astonishing how many business owners undervalue accounting and its profound financial impact on business operations, transactions, taxation, and profit. An effective accounting strategy captures the information required...more
Since 1916, Congress has exempted from income taxation clubs formed to facilitate social interaction between its members. As a result, country clubs, hunting and fishing clubs, college sororities and fraternities, and...more
If you are involved in a case where your spouse owns an interest in a small business, one of the issues you and your lawyer will grapple with is whether the books and records of that business adequately portray its revenue...more
In many ways, the labor market is as competitive as ever. Businesses continue to explore compensation packages, in addition to ordinary salary, that will help them attract, hire and retain talent. One method of compensation...more
Thirty years after the IRS first acknowledged that taxpayers could receive profits interests for services without immediate tax, the Tax Court has confirmed our long-held belief that the same protection is available for a...more
Every now and then, some well-meaning colleague will ask how I spend my free time. I usually pause before responding – to gather my thoughts – which prompts them to restate their question with what they believe is greater...more
The principal contention in the tax refund case of Exxon v. United States was whether certain mineral related transactions between Exxon and the countries of Qatar and Malaysia were sales or leases. Originally Exxon treated...more
Starting any business has risk, and most businesses take time to become profitable. Unfortunately, the IRS sees multiple years of losses from a business as a red-flag that usually results in further scrutiny. That scrutiny...more
On July 31, 2020, the Internal Revenue Service (IRS) published proposed regulations providing guidance under Section 1061 (the “Proposed Regulations”) of the Internal Revenue Code (the “Code”). Section 1061, which was added...more
On July 22, 2015, the U.S. Treasury Department and Internal Revenue Service released proposed regulations under Section 707(a)(2)(A) of the Internal Revenue Code relating to disguised payments for services between partners...more
On July 23, 2015, the Internal Revenue Service (“IRS”) issued a Notice of Proposed Rulemaking (the “Notice”) which proposed Treasury regulations under Section 707(a)(2)(A) of the Internal Revenue Code of 1986, as amended (the...more
In Internal Revenue Service Field Attorney Advice released May 22, 2015 (FAA 20152103F), the IRS Office of Chief Counsel expressed its informal view that the evidence suggests that the amount the taxpayer paid the United...more