Most Recent Posts
New Voice Of Gen-X Remembers 1994 When World Soccer Came To USA
So here is the deal 30 Days Across America is a great story. It's about America and New Jersey and the world, a bromance and a road trip, social class and even a bit...
Does Sixth Circuit ABC Decision Give Tenants Incentive To Buy?
Many older leases were written during periods of much higher interest rates. It would seem that there might be an opportunity here for owners of location-dependent businesses to pay something of a premium over fair market value, based on comparables, while coming out ahead on replacement cost with an immediate tax deduction sweetening the deal.
Cocaine Ponzi Schemes And Tax Prep – Not A Good Mix
Originally published on Forbes.com June 18th, 2014 Here's a tip if you are seeking to get started as a tax preparer. Don't go to work for somebody who also distributes...
Paul Reddam’s KPMG Tax Shelter Stunk In More Ways Than One
Tanina Rostain and Milton Regan in Confidence Games – Lawyers, Accountants, and the Tax Shelter Industry explained the ugly chapter in tax history that this deal is a small part of. The key to these transactions succeeding was the IRS never finding them. And the IRS probably would not have found most of them if KPMG and other firms had not been forced to turn over lists. Congress has been steadily eroding IRS capacity.
Personal Goodwill Avoids Corporate Tax Exposure
The impending suspension would cause customers to reevaluate whether to trust Bross Trucking and continue to do business with it. Indeed, Mr. Bross expressed his concern to his attorney that Bross Trucking might not be able to perform necessary functions as a result of the suspension. Mr. Bross’s solution was to find or create another business to take over the trucking needs for the Bross family businesses. This is the antithesis of goodwill: Bross Trucking could not expect continued patronage because its customers did not trust it and did not want to continue doing business with it.
Will National Grid Try Dumping Its Electrons Into Boston Harbor?
I have been reading about all this off-shore money and the proposals to squelch the way companies have been managing their tax liabilities, but a case like this makes me think that a lot of those arrangements might fall apart if the IRS had more resources to chase them. There is a brain drain from the IRS to the Big Four. Something tells me that if we were serious about the deficit the Government would reverse that brain drain and hire some of the best and the brightest from public accounting and industry tax departments. They would know where the bodies are likely buried.
Your Son The Lawyer Should Not Be Your Exchange Facilitator
Taxes are complicated and I do my best to simplify things when I can. The important concept about the “qualified intermediary” was that it not be someone who was your agent, since your agent touching the money was as bad as you touching the money. “Qualified intermediary” was to some extent defined negatively. I distilled it to a fairly simple rule. Anybody that a reasonable business person would trust to hold his money and follow his instructions to acquire the replacement property was disqualified. The QI could not be his lawyer, his accountant, his brother or his partner.
Confidence Games – How The Most Prestigious Accounting Firms Raided The Treasury
The greatest hazard that most CPAs face is envy. The hard reality of professional practice is that you either have to do some actual work yourself or pay somebody, probably pretty well, to do some work. Tax practices try to get around this by having a “leverage model” that “pushes work down” to the lowest paid person possible. Then there is that vast pool of highly educated South Asians that the internet makes available for compliance work. Neither of those courses is the road to great profitability.
Real Estate In Your IRA – How Not To Do It
Mr. Dabney honestly believed that the purchase was appropriate, even going to the trouble of obtaining a scrivener’s affidavit when he discovered that the property had been titled in the wrong name. He ensured that the funds were wired directly from the Charles Schwab IRA to Chicago Title when he first purchased the Brian’s Head property and directly back into the IRA after he had sold the property. Furthermore, the property was undeveloped, and Mr. Dabney ensured that it was being held solely for investment purposes.
Although he was mistaken in his understanding of the law, it was reasonable under the circumstances for Mr. Dabney to believe that he had not received an land.
Warning to Occupy Wall Street – Rape Can Still be Part of the Penalty
This was originally published on forbes.com on October 8 2011. It is a guest post by Tom Cahill. There are three words that I considered cutting, but left alone,...