Bar Exam Toolbox Podcast Episode 146: Listen and Learn -- Mortgages and Priority
On July 23, 2024, the U.S. Court of Appeals for the D.C. Circuit reversed the U.S. Tax Court in holding that inventory gain recognized by a nonresident alien individual partner on the sale of her interest in a U.S....more
Assume that X and Y agree to the following: X will transfer ownership of Prop to Y, and Y will transfer cash to X. What just happened? Obviously, X has sold Prop to Y. If the amount of cash that X receives is greater than...more
Although the IRS is now on high alert for wealthy individuals, new and existing planning opportunities are available, such as tax-free gifts and other advantageous planning. Wealthy individuals and families should take...more
Losses Weren’t Always Bad- Most tax advisers are aware that, prior to the Tax Reform Act of 1986 (the “TRA”),[i] the Code placed few limitations on the ability of an individual taxpayer to use deductions from a particular...more
Presented below is our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of October 31, 2022 – November 4, 2022....more
Head-Scratchers- The Code is chock-full of provisions that will challenge the intellectual capacity, not to mention the patience, of most tax professionals. The complexity of these rules does not arise out of some sadistic...more
Ask the owner of a closely held business to describe their most recently recurring nightmare and you are likely to get an earful regarding the prospect of an increased federal income tax on their profits, an increased federal...more
A closely held business may come to our firm for any number of reasons. The owners may be selling the business, for example, or they may be thinking about spinning off a division. In some cases, the owners are considering the...more
At this time, unless Congress acts, the current lifetime estate tax exemption amount of $11,580,000 is set to sunset in 2025, which means that in 2026 it will revert to $5,000,000 per person, adjusted for inflation. Many...more
To reduce risk of later attack on the domestic partnership agreement, domestic partners should make fair and reasonable financial disclosures to each other prior to signing the agreement. Each partner should disclose to the...more
In Mingo v. Comm’r the 5th Circuit upheld a Tax Court decision and denied installment sale treatment to the extent the partnership interest sold related to underlying unrealized receivables. The taxpayer sold its interest in...more