The Internal Revenue Code permits a business bad debt deduction when a customer fails to pay for the services rendered or the products supplied by your business. However, the ability to claim an ordinary deduction with...more
3/22/2024
/ Bankruptcy Code ,
Commercial Bankruptcy ,
Creditors ,
Debtor-Creditor ,
Debtors ,
Financial Services Industry ,
Insolvency ,
Internal Revenue Code (IRC) ,
IRS ,
Tax Deductions ,
Tax Liability
Summary -
On November 28, the Tax Court, granting the Internal Revenue Service (IRS) summary judgment, held in Soroban Capital Partners LP v. Commissioner that a state law limited partner who is limited in name only, is...more
In our continuing series on Section 704(c) of the Internal Revenue Code (the Code) we discuss the application of the remedial method to correct for distortions caused by the ceiling rule. As previously discussed, when the tax...more
11/2/2023
/ Fair Market Value ,
Income Taxes ,
Internal Revenue Code (IRC) ,
IRS ,
Limited Liability Company (LLC) ,
Partnerships ,
Private Equity ,
Private Equity Firms ,
Property Ownership ,
Remedial Actions ,
Tax Liability ,
Tax Planning
In Part 1 of our discussion on Section 704(c) (Part 1) we described the basic idea of how the inherent built-in tax gain or loss on a piece of property contributed to a partnership is allocated to the contributing partner. As...more
10/19/2023
/ Capital Gains ,
Capital Losses ,
Income Taxes ,
Internal Revenue Code (IRC) ,
IRS ,
Limited Liability Company (LLC) ,
Partnerships ,
Private Equity ,
Private Equity Firms ,
Property ,
Tax Liability ,
Tax Planning
When entering into a partnership agreement where one partner is contributing cash and another partner is contributing appreciated property, inevitably, a tax advisor is going to ask, which Section 704(c) allocation method...more
On May 19, 2023 the Internal Revenue Service (IRS) released AM 2023-003 (the Memo or GLAM) holding that the Foreign Investment in Real Property Tax Act’s (FIRPTA’s) 5% publicly traded exception (the 5% exception) applies at...more