Belan Wagner
Compensation for a victim’s injuries in a personal injury accident is typically made by an insurance company. In California, insurance companies owe three duties to the person whom they have insured (the “policyholder”): (1) duty to defend a claim (or lawsuit) even if some or most of the lawsuit is not covered by the policy; […]
READ MOREThis article addresses the tax consequences arising from the relief or cancellation of debt (“Mortgage Relief”) arising from a foreclosure, short sale or deed in lieu of foreclosure (“PR Disposition”) or loan workout with respect to a debt (“Home Mortgage” ) secured by a taxpayer’s principal residence (“PR” ). Click here to download a PDF […]
READ MOREThis issue of the WKBK&Y newsletter addresses Family Limited Partnerships as Estate Planning Tools. For a while, practitioners can still use family limited partnerships or limited liability companies as vehicles to accomplish estate planning goals (both referred to as “FLPs” herein). While the IRS keeps litigating the validity of FLPs under a variety of theories […]
READ MOREAllocation of Debt Among Partners in Tiered Partnershipsc
This month’s newsletter focuses on allocation of debt among partners in tiered partnerships. Last month we reviewed the fundamentals of debt allocation under Section 752. This month we are going to look at a particular entity structure and discuss how the anti-abuse rules under Section 752 would apply. The structure is a limited partnership with […]
READ MOREIRC 752 – Allocation of Debt Among Partners
This month’s newsletter focuses on an oldie but goodie: IRC 752 — Allocation of debt among partners — the fundamentals. For various reasons, we have been called up on to consult with accounts on the allocation of liabilities among partners — remember those boxes you have to check on the K-1’s? Almost invariably the liability […]
READ MORETax Services Newsletter – Treatment of Losses from an Abandonment
This issue of the WKBK&Y newsletter addresses: Tax Treatment of Losses from an Abandonment or Worthlessness of a Partnership Interest — Capital or Ordinary Accrual Accounting of Rebate Offers – CCA 200826006 Two Bills in Congress to Reform the Estate Tax IRS Considering Benefits for Private Trust Companies Serving as Trustees Click here to download […]
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