Most Recent Posts
Structured Installment Sale Can Be A Great Solution To Liquidity Event Tax
Rising interest rates have brought one technique to the fore that had gone out of favor- the structured installment sale (SIS). For what it is worth, if I had another ship come in this is the technique that I would likely go with.
Missing Tax Court Deadline By A New York Minute
Cases where the problems that lead to late filing of Tax Court petitions have been a staple of this blog and are the source of Reilly’s Seventeenth Law of Tax Planning – “Don’t cut your deadlines close and use the US Mail with proof of mailing.
Employee Retention Credit Schemes Are Symptom Of A Dysfunctional Tax System
Lance Wallach is an expert on abusive tax transactions - in a good way. He warns people about them and then helps the ones who didn't hear his warnings or did not take...
Hobby Loss Roundup
Although I fell in love with Section 183 cases because they tend to be such great stories and so amusing, that will not be the focus of my seminar. My study of the case law and detailed analysis of over 300 cases has caused me to conclude that key elements of the section are misunderstood by many practitioners (and the public which pretty much goes without saying) and that practitioners tend to be too conservative in counseling clients. The focus of my seminar will be coaching clients and winning audits.
District Court Tosses Interesting Likely Frivolous Tax Argument Out On Standing
The uniformity rule also applies to “incorporated territories”. As most people see it, there is not much in the way of incorporated territory since Alaska and Hawaii became states in 1959. There is some. 4.6 acres with no permanent residents – Palmyra Atoll. Brian sees it differently. He thinks Puerto Rico is an incorporated territory because it is clearly on the road to statehood.
Alternative Tax Thinker Trying The Puerto Rico Gambit
“The Insular Cases have no foundation in the Constitution and rest on racist stereotypes. They deserve no place in our law.”
Year 15 Low Income Housing Tax Credit Fight Turns Ugly For CohnReznick
The regulations under 704(b) have a concept called “minimum gain”. Minimum gain places a limit on the amount of losses that can be allocated to a limited partner beyond their contribution, simplistically that is how far negative their capital account can go. If you want to dig into the details and explanations of CohnReznick’s computations they are available here in exhibits in the Mass Superior Court litigation. It is hard to see how liabilities could have been counted as going into minimum gain, but have them still hanging after disposition of the property.
Plan On Having The Death Tax Live On
Firms like Withersworldwide devise plans, draft documents and see that the documents are properly executed and store them. Then they will review and revise the plan based on changes in the laws or changes in the circumstances of the family they are planning. The actual execution of the plan falls to trustees, family offices, the family members themselves and my people – accountants.
Trump Indictment – 34 Counts Of Falsifying – What Is The Other Crime?
Here is the tax thing about legal expense. Is a legal expense deductible ? Well it depends. Until 2021 Trumps return was done by a firm called Mazars. Mazars is rated number 30 in Accounting Today’s latest top 100. I am going to go out on a limb and speculate that Trump was the most famous client of Mazars. So the team doing the return is probably not a bunch of people who just fell off the turnip truck. If I was the TO CFO and I was looking to bury this expense so it would be deducted without question the last account I would have it be paid out of is Trump’s personal account. That is the account which seems most likely to include nondeductible legal expenses.
Third Circuit Upholds Tax Court In Large Dollar Horse Hobby Loss Opinion
He mentioned the Dreicer decision which is actually a sort of hilarious story of a trustifarian touring the world in search of the perfect steak. Dreicer lost in Tax Court and appealed to the DC Circuit (he was an expat). The Tax Court judge had indicated that it was not reasonable to expect a profit from the activity. The DC Circuit sent the case back to the Tax Court indicating that that was not the correct standards. What you have to have is the objective of making a profit, not the expectation. Back at the Tax Court again Dreicer still lost, but I give him credit for inspiring Reilly’s Eighteenth Law of Tax Planning – Honest objective trumps realistic expectation