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N. Aaron Johnson

Tax Issue Spotting During the Lifecycle of a Startup

March 14, 2016

To view this presentation on tax issues relating to the formation of a startup business, click here to download a PowerPoint copy. Tax Issue Spotting During the Lifecycle of a Startup – Choice of Entity Considerations from WKBK&Y LLP

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Clarifying Standards for Trade or Business Real Estate Debt

September 11, 2015

In this article, Johnson and Harmon argue that real estate lessors, developers, and dealers who realize cancellation of debt income attributable to acquisition debt for real property should be able to avail themselves of the exclusion for the discharge of qualified real property business indebtedness. Accordingly, they urge the IRS to clarify the definition of […]

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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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