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Internal Revenue Code (IRC) Business Losses

Foster Garvey PC

Hobby Loss Rules Revisited

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With the Corporate Transparency Act hopefully in our rearview mirrors, I decided to take a brief break from my ongoing series on Subchapter S and report on a different topic. In the last few weeks, the Magistrate Division of...more

Foster Garvey PC

A Journey Through Subchapter S / A Review of The Not So Obvious & The Many Traps That Exist For The Unwary: Part XVI – Changes in...

Foster Garvey PC on

Now that the scurrying around and worrying relative to developments impacting the Corporate Transparency Act (“CTA”) that were coming at us with laser speed are on a slow simmer, I can turn my attention back to my multi-part...more

Foster Garvey PC

A Journey Through Subchapter S / A Review of The Not So Obvious & The Many Traps That Exist For The Unwary: Part XI – A...

Foster Garvey PC on

In this Part XI of my multi-part series on some of the not-so-obvious aspects of S corporations, I explore a topic that should be obvious but which appears to be ignored by many taxpayers and their tax advisers – accurate...more

Holland & Knight LLP

IRS Targets Owners of Professional Sports Franchises Regarding Tax Reporting

Holland & Knight LLP on

Basketball just wrapped up its season and hockey is in the last period of its season, but there is no summer vacation for the IRS Large Business and International (LB&I) division. The IRS recently announced a new enforcement...more

ASKramer Law

Weather & Climate Risk Management Part IV: Taxation of Weather Risk Management Products

ASKramer Law on

Are there differences in the way in which weather derivatives and weather insurance are taxed? Yes. Weather insurance products, including parametric insurance, are taxed as insurance; and derivatives are taxed in accordance...more

Foster Garvey PC

A Journey Through Subchapter S / A Review of The Not So Obvious & The Many Traps That Exist For The Unwary: Part IV – Suspended...

Foster Garvey PC on

This fourth installment of my multi-part series on Subchapter S is focused on suspended losses of an S corporation. While the rules seem straightforward, their application can be tricky, especially given legislative changes...more

Freeman Law

Donkeys and Taxes

Freeman Law on

Hobby Loss or Business Loss Tax Deduction - It’s not every day that a case comes through the Tax Court centered on the taxation of miniature donkey breeding. But the recent case of Huff v. Commissioner was focused on just...more

Foster Garvey PC

House of Representatives 5376: Current Tax Legislation Pending in the U.S. House of Representatives

Foster Garvey PC on

...The federal tax laws are certainly about to change. With the need to raise revenue as a top priority for the Biden Administration, everyone is expecting dramatic changes to the Internal Revenue Code. Tax legislation is...more

Eversheds Sutherland (US) LLP

State of play: A May methods update 

At last week’s ABA May Tax Meeting, government attorneys from both the Internal Revenue Service National Office Income Tax & Accounting division (IT&A) and the Department of the Treasury provided updates to taxpayers and...more

Burr & Forman

Cannabis Business Takes Position That § 280E Is Unconstitutional – And It’s Like a Grocery Store For Adults

Burr & Forman on

Cannabis (or marijuana) dispensaries have long stated that they are subjected to harsher tax consequences under the Internal Revenue Code (“IRC” or “Code”) than their “legal” counterparts. Specifically, they have argued, in...more

Troutman Pepper Locke

When Does a Loan Guarantee Provide Amounts at Risk - Tax Update, Volume 2020, Issue 3

Troutman Pepper Locke on

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

Bowditch & Dewey

How Can a Craft Brewer Use the Tax Code to Help with Cash Flow?

Bowditch & Dewey on

Breweries can turn to the Internal Revenue Code to help with cash flow in these difficult times. Section 165(i) of the Internal Revenue Code allows a taxpayer to deduct any loss occurring in a “disaster area” and attributable...more

McGlinchey Stafford

What does the CARES Act mean for net operating losses and non-corporate business losses?

McGlinchey Stafford on

The CARES Act temporarily suspends retroactively changes made to the treatment of net operating losses by the 2017 Tax Cuts and Jobs Act (the “2017 Tax Act”). It also suspends retroactively the limitation on excess business...more

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