Jason Freeman

Jason Freeman

Freeman Law

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Insider Trading Law | An Evolving Landscape

Throughout the history of the U.S. stock market, individuals have used insider access to information to gain an unfair advantage over other investors. The use of material non-public information (“MNPI”) in financial trading...more

3/25/2024 / Enforcement Actions , Illegal Tipping , Insider Trading , Material Nonpublic Information , Personal Benefit , Securities and Exchange Commission (SEC) , Securities Fraud

Employee Stock Ownership Plans | A Brief Overview

Since their establishment in 1974, Employee Stock Ownership Plans (“ESOPs”) have become a popular and effective mechanism for private companies (both C corporations and S corporations) to provide employees an opportunity to...more

3/22/2024 / Department of Labor (DOL) , EBSA , Employee Benefits , Employee Retirement Income Security Act (ERISA) , ESOP , Internal Revenue Code (IRC) , IRS , Stock Ownership

Tax Court in Brief | Scheizer v. Comm’r | Charitable Contribution Substantiation and Reliance on Tax Professional

Tax Litigation: The Week of October 3rd, 2022, through October 7th, 2022 Sander v. Comm’r, T.C. Memo. 2022-103 | October 6, 2022 | Morrison, J. | Dkt. No. 22472-16...more

10/25/2022 / Income Taxes , IRS , Tax Court , Tax Deductions , Tax Liability , Tax Planning , Tax Returns , Treasury Regulations

Tax Court in Brief | Sander v. Comm’r | Standing to Contest Deficiency of Another

Tax Litigation: The Week of October 3rd, 2022, through October 7th, 2022 Scheizer v. Comm’r, T.C. Memo. 2022-102 | October 6, 2022 | Lauber, J. | Dkt. No. 3679-18 Sander v. Comm’r, T.C. Memo. 2022-103 | October 6, 2022 |...more

10/24/2022 / Income Taxes , IRS , Tax Liability , Tax Planning , Tax Returns

Tax Court in Brief | Patitz v. Comm’r | Schedule A and Schedule C Itemized Deductions and Documentation Requirements

Tax Litigation: The Week of September 26th, 2022, through September 30th, 2022 Powell and Iakovenko v. Comm’r, T.C. Summary Opinion, 2022-19 | Sept. 26, 2022 | Copeland, J. | Docket No. 20268-19S Powell and Iakovenko v....more

10/19/2022 / Income Taxes , IRS , Itemized Deductions , Tax Court , Tax Deductions , Tax Liability , Tax Planning , Tax Returns

Tax Court in Brief | Collins v. Comm’r | Innocent Spouse Requests a Refund for Which He Did Not Pay; Denied

Tax Litigation: The Week of September 26th, 2022, through September 30th, 2022 Patitz, Moody v. Comm’r, T.C. Memo. 2022-99 | September 27, 2022 | Weiler, J. | Dkt. No. 2784-19 Powell and Iakovenko v. Comm’r, T.C. Summary...more

10/19/2022 / Income Taxes , Innocent Spouse Exception , IRS , Joint Tax Returns , Tax Court , Tax Deductions , Tax Liability , Tax Planning , Tax Relief , Tax Returns

Tax Court in Brief | Powell v. Comm’r | IRS Forms vs. Statutes – Net Capital Loss Deduction

Tax Litigation: The Week of September 26th, 2022, through September 30th, 2022 Patitz, Moody v. Comm’r, T.C. Memo. 2022-99 | September 27, 2022 | Weiler, J. | Dkt. No. 2784-19 Powell and Iakovenko v. Comm’r, T.C. Summary...more

10/19/2022 / Capital Losses , Income Taxes , IRS , Tax Court , Tax Deductions , Tax Liability , Tax Planning , Tax Returns

Tax Court in Brief | Ashford v. Comm'r | Unreported Income, Additions to Tax, Frivolous Arguments, Taxable Income

Tax Litigation: The Week of September 26th, 2022, through September 30th, 2022 Patitz, Moody v. Comm’r, T.C. Memo. 2022-99 | September 27, 2022 | Weiler, J. | Dkt. No. 2784-19 Powell and Iakovenko v. Comm’r, T.C. Summary...more

10/18/2022 / Income Taxes , IRS , Tax Court , Tax Deductions , Tax Liability , Tax Planning , Tax Returns

Tax Court in Brief | Powell and Iakovenko v. Comm’r | Schedule D to Form 1040 & Advance Premium Tax Credit

Tax Litigation: The Week of September 26th, 2022, through September 30th, 2022 Patitz, Moody v. Comm’r, T.C. Memo. 2022-99 | September 27, 2022 | Weiler, J. | Dkt. No. 2784-19 Powell and Iakovenko v. Comm’r, T.C. Summary...more

10/18/2022 / Income Taxes , IRS , Tax Court , Tax Deductions , Tax Liability , Tax Planning , Tax Returns

Tax Court in Brief | Furrer v. Comm'r | Charitable Remainder Trusts; Non-Cash Charitable Contribution Substantiation; Taxability...

Tax Litigation: The Week of September 26th, 2022, through September 30th, 2022 Patitz, Moody v. Comm’r, T.C. Memo. 2022-99 | September 27, 2022 | Weiler, J. | Dkt. No. 2784-19 Powell and Iakovenko v. Comm’r, T.C. Summary...more

10/17/2022 / 501(c)(3) , Charitable Deductions , Income Taxes , IRS , Tax Court , Tax Exemptions , Tax Liability , Tax Planning , Tax Returns

Tax Court in Brief | Vorreyer v. Comm’r | Thoma v. Comm’r | Dowson v. Comm’r | Deductibility of S Corp Expense Paid by Shareholder

Tax Litigation: The Week of September 19th, 2022, through September 22nd, 2022 Goddard v. Comm’r; Lee, Goddard, & Duffy, LLP v. Comm’r, T.C. Memo 2022-96| September 19, 2022 | Copeland, Judge | Dkt. No. 22334-17L, 23743-18L...more

10/14/2022 / Income Taxes , IRS , S-Corporation , Tax Court , Tax Liability , Tax Planning , Tax Returns

Tax Court in Brief | Goddard v. Comm'r | Collection Due Process, Penalties for Failure to Register a Tax Shelter

Tax Litigation: The Week of September 19th, 2022, through September 22nd, 2022 Vorreyer v. Comm’r / Thoma v. Comm’r / Dowson v. Comm’r, T.C. Memo 2022-97| September 21, 2022 | Greaves, Judge | Dkt. Nos. (Consolidated)...more

10/14/2022 / Income Taxes , IRS , Tax Court , Tax Debt , Tax Liability , Tax Liens , Tax Planning , Tax Returns , Tax Shelters

Tax Court in Brief | Estate of Clemons v. Comm’r | Dangers of FBAR, Accuracy-Related Penalties, and Foreign Assets

Tax Litigation: The Week of September 12th, 2022, through September 16th, 2022 Degourville v. Comm’r, T.C. Memo. 2022-93 | September 12, 2022 | Wells, J. | Dkt. No. 4369-16 Fabian v. Comm’r, T.C. Memo 2022-94| September 13,...more

10/3/2022 / FBAR , Income Taxes , IRS , Tax Court , Tax Deductions , Tax Liability , Tax Planning , Tax Returns

Tax Court in Brief | Degourville v. Comm’r | Earned Income Tax Credit, Head of Household Status, and “Badges of Fraud”

Tax Litigation: The Week of September 12th, 2022, through September 16th, 2022 Fabian v. Comm’r, T.C. Memo 2022-94| September 13, 2022 | Halpern, Judge | Dkt. No. 25589-14 Estate of Clemons v. Comm’r, T.C. Memo. 2022-95|...more

10/3/2022 / Income Taxes , IRS , Tax Court , Tax Deductions , Tax Liability , Tax Planning , Tax Returns

Tax Court in Brief | Fabian v. Comm’r | Fraudulent Returns, Constructive Receipt, and Guilty Plea | Don’t be Like Fabian

Tax Litigation: The Week of September 12th, 2022, through September 16th, 2022 Degourville v. Comm’r, T.C. Memo. 2022-93 | September 12, 2022 | Wells, J. | Dkt. No. 4369-16 Estate of Clemons v. Comm’r, T.C. Memo. 2022-95|...more

10/3/2022 / Income Taxes , IRS , Joint Tax Returns , Tax Court , Tax Deductions , Tax Liability , Tax Planning , Tax Returns

International Tax Concepts: Tax Residency Status

U.S. Tax Residency Status - As a general matter, all U.S. citizens and U.S. residents are treated as U.S. tax residents. A non-U.S. citizen is generally classified as a nonresident for U.S. tax purposes unless they satisfy...more

10/3/2022 / Green Cards , Income Taxes , International Tax Issues , IRS , Lawful Permanent Residents , Non-Resident Aliens , Non-Resident Income Taxes , Physical Presence Test , Residency Status , Substantial Presence Test , Tax Treaty

Revoking a Mark-to-Market Election with Respect to a Foreign Company

A taxpayer with shares in a passive foreign investment company (a “PFIC”) may qualify to make either a qualified electing fund (“QEF”) election or an election to apply mark-to-market treatment with respect to marketable...more

9/29/2022 / Foreign Corporations , International Tax Issues , IRS , Passive Foreign Investment Company , PFIC , Private Letter Rulings , Securities Exchange Act

Tax Court in Brief | Clarkson v. Comm’r | Frivolous Return Penalties and “Zero Returns”

Tax Litigation: The Week of September 5th, 2022, through September 9th, 2022 Clarkson v. Comm’r, T.C. Memo 2022-22| September 7, 2022 | Lauber, Judge | Dkt. No. 16804-21L...more

9/29/2022 / Deficiency Notices , Income Taxes , Internal Revenue Code (IRC) , IRS , Standard of Review , Tax Court , Tax Liability , Tax Planning , Tax Returns

Country-by-Country Reporting: VIEs, PEs, Grantor Trusts and Other Nuances

International tax issues sit high on the political agenda for most countries. Among those issues, few rank higher than transfer pricing policies. Recent years have seen a trend toward Country-by-Country (CbC) reporting,...more

9/29/2022 / Base Erosion Tax , BEPS , Corporate Taxes , Income Taxes , International Tax Issues , OECD , Tax Planning , Tax Reform , Transfer Pricing

Country-by-Country Reporting

In recent years, tax authorities across the globe have adopted a number of OECD-led initiatives aimed at curbing the ability of multinational enterprises to engage in so-called Base Erosion and Profit Shifting (BEPS) (i.e.,...more

9/27/2022 / BEPS , Country-by-Country , GAAP , Income Taxes , International Tax Issues , OECD , Tax Liability , Tax Planning , Tax Returns

International Tax Concepts: Dual-Status Taxpayers

A taxpayer’s status as a resident or nonresident is not always straightforward. A dual-status taxpayer, for example, may qualify as both a nonresident alien and a resident alien during the same tax year. Typically, this...more

9/27/2022 / Corporate Taxes , Dual Citizenship , Income Taxes , International Tax Issues , IRS , Non-Resident Income Taxes , Tax Court , Tax Deductions , Tax Liability , Tax Returns

The Taxpayer Bill of Rights

The Internal Revenue Code provides for the Taxpayer Bill of Rights. The Taxpayer Bill of Rights reflects a mandate that the IRS provide a level of service. The Bill of Rights raises questions, such as whether it is...more

9/27/2022 / Income Taxes , Internal Revenue Code (IRC) , IRS , Tax Court , Tax Liability , Tax Litigation , Taxpayers' Bill of Rights

Tax Court in Brief | Butterfield v. Comm’r | Travel Reimbursements and Itemized Deductions

Tax Litigation: The Week of August 29th, 2022, through September 2nd, 2022 Sparta Pink Property, LLC v. Comm’r, T.C. Memo. 2022-88 | August 29, 2022 | Lauber, J. | Dkt. No. 12114-20 Pressman v. Comm’r, T.C. Summ. Op. 2022-15...more

9/27/2022 / Business Expenses , Income Taxes , IRS , Itemized Deductions , Tax Court , Tax Deductions , Tax Liability , Tax Planning , Tax Returns

Tax Court in Brief | Luna v. Comm’r | Disallowance of Itemized Business Deductions and Lack of Substantiation

Tax Litigation: The Week of August 29th, 2022, through September 2nd, 2022 Sparta Pink Property, LLC v. Comm’r, T.C. Memo. 2022-88 | August 29, 2022 | Lauber, J. | Dkt. No. 12114-20 Pressman v. Comm’r, T.C. Summ. Op. 2022-15...more

9/26/2022 / Business Expenses , Income Taxes , IRS , Itemized Deductions , Tax Court , Tax Deductions , Tax Liability , Tax Planning , Tax Returns

Tax Court in Brief | Lamprecht v. Comm’r | Qualified Amended Return and Foreign Banking Reporting

Tax Litigation: The Week of August 29th, 2022, through September 2nd, 2022 Sparta Pink Property, LLC v. Comm’r, T.C. Memo. 2022-88 | August 29, 2022 | Lauber, J. | Dkt. No. 12114-20 Pressman v. Comm’r, T.C. Summ. Op....more

9/23/2022 / Amended Tax Returns , Department of Justice (DOJ) , Foreign Bank Accounts , Income Taxes , IRS , John Doe Investigation , Summons , Tax Liability

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