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Doug Youmans

CCP 580e Gives Rise to Non-recourse Treatment of Discharged Debt

May 10, 2015

In response to a letter Senator Boxer sent to the Internal Revenue Service (the “Service”) last year, requesting clarification as to whether a short sale conducted pursuant to California Code of Civil Procedure (“CCP”) §580e resulted in cancellation of indebtedness (“COI”) income, the Service issued Information Letter Number 2013-0036 (“ILN 2013-0036”).  ILN 2013-0036 states, “We […]

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Tax Considerations in Choosing and Forming a Business Structure or Entity

September 14, 2014

Factors affecting the “choice of entity” can (should) include: Owner liability; Owner control and participation in management; Reporting and taxation of income; Changes in ownership – withdrawal, retirement and the like; Allocations of profits and losses; Rights among owners with respect to dispute resolution; and Licensing (e.g., LLCs in California). Under California law, providers of […]

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Tax Considerations in Choosing and Forming a (Business) Structure or Entity

September 11, 2014

To view this presentation on tax considerations when forming a business entity offline, click here to download a PowerPoint copy. Tax Considerations in Choosing and Forming a (Business) Structure or Entity from WKBK&Y LLP Further information can be found by clicking this link for a full length article.

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Substantiating (Substantial) Contributions – Oh, What a Relief It Is!

November 12, 2013

To view this presentation on substantiating contributions offline, click here to download a PowerPoint copy. Substantiating (Substantial) Contributions – Oh, What a Relief It Is! from WKBK&Y LLP More information from WKBK&Y on this subject can be found on this article.

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Substantiating (Substantial) Contributions—Oh, What a Relief It Is!

November 12, 2013

These materials outline what the IRS and the courts are focusing on when looking at appraisals being submitted to substantiate valuations claimed for transfer tax or income tax reporting purposes.  The subjects addressed include: Substantiation Needed; Applicable Penalties; and Penalty Avoidance/Defenses To read this article in full, click here to download a PDF copy.

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Don’t Leave Home Without It – Estate and Gift Tax Conference

March 1, 2013

Estate and Gift Tax Returns: Gift Tax.  The “adequate disclosure” Regs (Regs. §301.6501(c)-1(f)) require the following to toll the statute of limitations (to apprise the IRS of the “nature of the gift and the basis for the value so reported): a detailed description of the method used to determine the value; any financial data utilized […]

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