Net Investment Income Tax – What You Don’t Know Will Cost You
Overview - Patient Protection and Affordable Care Act Many individuals, estates and trusts will be facing new taxes ...
Don’t Leave Home Without It – Estate and Gift Tax Conference
Estate and Gift Tax Returns: Gift Tax. The “adequate disclosure” Regs (Regs. §301.6501(c)-1(f)) require the following to toll ...
Partnership Tax and Disguised Sales §704(c)(1)B
There are several disguised sale rules under Subchapter K. IRC Sections 707(a)(2)(B), 704(c)(1)(B), 737 and 751(b). Needless to ...
Update on the Fiscal Cliff
The following is a cheat sheet on the Fiscal Cliff Avoidance – aka American Taxpayer Relief Act of ...
Modifying an Option Agreement? It May Be Considered a New Agreement for Tax Purposes.
PAYMENTS RECEIVED UNDER OPTION AGREEMENT ARE NOT TAXED UNTIL EXERCISE OR LAPSE “An option is a contract which ...
Satisfying Personal Injury Judgment with Settlement Proceeds from a Bad Faith Claim
Compensation for a victim’s injuries in a personal injury accident is typically made by an insurance company. In ...
U.S. Estate and Gift Tax Concerns for Foreign Assets
Most tax practitioners understand that the United States will tax a resident’s worldwide income and will impose estate ...
Should Buyers Require the Seller to be a Consultant?
Every business broker will probably agree that a covenant not-to-complete makes good business sense. No buyer would ever ...
File Form 8938 with Form 1040 to Report Certain Foreign Financial Assets
Preparers are going to have to be a lot more inquisitive with their client’s 2011-year personal income tax ...
2012 Changes to IRS Form 2848
After December 31, 2011, the IRS will no longer be accepting the old Form 2848. For practitioners, there are ...
Taxation of Domestic Partners
AB 205, as amended by AB 2580, the Domestic Partner Rights and Responsibilities Act (“Act”), was a complicated ...
IRS Announces Relief Program for Undisclosed Offshore Accounts and Assets
The IRS has recently adopted its second taxpayer relief period for unreported offshore accounts and assets. The IRS’s ...
Tax Legislative Update – Obama Administration Tax Laws
On February 17, 2009, President Obama signed the American Recovery and Reinvestment Act of 2009 (“ARRA”) into law. ...
Between the Sheets or Splitting the Sheets
AB 205, as amended by AB 2580, the Domestic Partner Rights and Responsibilities Act (“Act”), was a complicated ...
Suggested Procedure for Filing and Perfecting Protective Claims Under Treasury Regulations §20.2053-1
IRC §2053(a)(3) states, in relevant part, that, “[f]or purposes of [the federal estate tax], the value of the ...
Navigating Audit, Appeals and Litigation: The IRS’ Perspective
Power of Appointment Causes-Inclusion in Decedent's Estate Technical Advice Memorandum 200907025 (TAM 200907025) Decedent was the sole beneficiary ...
2009 Annual Washington D.C. Delegation
With over 3,000 members, the Taxation Section of the California State Bar is one of the largest tax ...
How to Avoid Indirect-Gift Treatment Under the Step Transaction Doctrine
Gross v. Commissioner (T.C. Memo. 2008-221, September 29, 2008) Ms. Gross formed a limited partnership (Dimar) in July ...
Bankruptcy Fundamentals and Residential Mortgage Default Issues
Types of Insolvency Proceedings Assignments for the Benefit of Creditors. Common law provides that a debtor can make ...
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