Background -
Sections 162(f) and 6050X changed the requirements for taxpayers to deduct amounts paid to the government or at its direction under court-ordered judgments, settlement agreements, non-prosecution agreements,...more
An individual donating land to a municipality simultaneously when seeking to obtain development approvals from that same municipality often encounters the issue of whether the contribution lacked charitable intent and if the...more
On April 24, 2020, the U.S. Treasury Department and Internal Revenue Service issued proposed regulations with respect to Section 512(a)(6) of the Internal Revenue Code. These regulations are designed to provide guidance on...more
7/30/2020
/ Aggregation Rules ,
Control Test ,
De Minimis Claims ,
Income Taxes ,
Internal Revenue Code (IRC) ,
IRS ,
Limited Liability Company (LLC) ,
Partnerships ,
Proposed Regulation ,
Tax Cuts and Jobs Act ,
U.S. Treasury ,
UBTI
In Bordelon v. Commissioner, the Tax Court addressed the circumstances under which an individual’s personal guarantee of a loan to his single-member LLC established sufficient amounts at risk to enable him to claim more than...more
The recently enacted Coronavirus Aid, Relief, and Economic Security Act (CARES Act), as well as IRS guidance released in the last few days, aim to provide real estate businesses, among others, with decreases or delays in...more
Consider the following hypothetical: Bill and his wife, Melinda, are the sole owners of Microfix, Inc., a successful computer repair business....more
Tax-exempt organizations that have unrelated business taxable income (UBTI) may need to calculate their UBTI differently as a result of a change in the tax law made by the Tax Cuts and Jobs Act of 2017 (TCJA). ...more
3/11/2019
/ Business Taxes ,
De Minimus Quantity Exemption ,
Income Taxes ,
IRS ,
NAICS ,
Tax Cuts and Jobs Act ,
Tax Deductions ,
Tax Exempt Entities ,
Tax Planning ,
Tax Reform ,
UBTI
THE NEW REGULATIONS EXPAND THE FILING REQUIREMENTS FOR FORM 5472 TO INCLUDE DISREGARDED ENTITIES WITH FOREIGN OWNERS WHEN THERE ARE CERTAIN REPORTABLE TRANSACTIONS.
If a non-U.S. person (individual or corporation)...more
Tax season has begun, and it is crucial for any taxpayer claiming a charitable contribution deduction to be aware of the acknowledgment rules. Before the taxpayer files a tax return claiming a charitable deduction of $250 or...more
Taxpayers who make payments in conjunction with a forfeiture action should attempt to understand the characterization of a payment to see if the specific payment can avoid being treated as a fine or penalty.
Originally...more
11/22/2016
/ Disgorgement ,
Financial Industry Regulatory Authority (FINRA) ,
Fines ,
IRS ,
Penalties ,
Section 162(f) ,
Securities and Exchange Commission (SEC) ,
Securities Exchange Act ,
Securities Violations ,
SRO ,
Tax Deductions ,
Tax Returns
Investments in partnerships (and other pass-through entities such as limited liability companies treated as a partnership) often involve the acquisition of warrants, options or other rights to acquire securities. This is...more
The issue of whether a trust has passive or non-passive income from its investment in a pass-through entity has taken on increased importance in light of the tax imposed on net investment income under Code Section 1411 of the...more
Whether a business may deduct litigation settlement payments can have a substantial real dollar impact on the business. In the midst of combating potential litigation, companies rarely first focus on the potential tax impact...more
In an important recent decision, United States v. Quality Stores, Inc., et al., Case No. 01-1563, 2012 U.S. App. LEXIS 18820 (6th Cir. Sept. 7, 2012), the U.S. Court of Appeals for the Sixth Circuit held that supplemental...more
In September 2011 the Internal Revenue Service (IRS) announced a new voluntary relief program for worker status termed the voluntary classification settlement program (VCSP). Announcement 2011-64, 2011-41, I.R.B. 503. On...more