Most Recent Posts
Roots Of The 250% Solution To Charitable Easement Tax Abuse
The 2.5 limit knocks out the most egregious abuse, but it still strikes me as overly generous. If I was going to put in a limit it would probably be 90% on a three year hold and gradually rise. Remember the deduction is for an easement on the property. And unless you drink the Kool-Aid mixed by Partnership For Conservation (P4C), as easement can’t be worth more than the property itself.
Oakbrook Land Holdings A Major 2020 Tax Court Decision
The conservation deed was problematic for two reasons. It took the value of any subsequent improvements off the top of any extinguishment proceeds and it gave the donee the fixed amount determined at the time of donation.
IRS At Supreme Court Over Captive Insurance
“Turn their risks into wealth” ?? If the wheels that spin straw into gold are not working, you have to do the best you can.
I spoke with a tax executive for a major life insurance company. Promoters had been trying to get the company’s sales force to recommend captive insurance deals. When he examined them he concluded that there was not actually much in the way of insurance going on. It looked more like alchemy.
Bob Dylan’s Debt To Nashville – It’s About Taxes
Dylan’s reach was really amazing. Sister Kathleen Reilly, who was a year younger than Dylan, told me that when the older nuns at the Pallotine motherhouse in Harriman, NY were upset about various things that were different from the good old days of habit wearing, the younger nuns would break into a chorus of The Times They Are A Changin’.
Vacation Home Conversion, Debt Discharge And Partnership Issues All In One Tax Court Case
When you borrow money secured by property whether the debt is recourse or nonrecourse can have tremendous tax significance. From an economic viewpoint, you want the debt to be nonrecourse. The idea is that if you can’t pay, you hand the bank keys and you are done. Sometimes though you can get that deal with recourse debt. It is called a “short sale”, which has a different meaning in real estate than it does on Wall Street.
Law Professor Argues Opportunity Zone Program Is Harmful
It seems though that the impetus to tinker with the Code to achieve goals other than raising the right amount of revenue with the least collateral damage is irresistible. Tax expenditures have a way of seeming like a free lunch. So when a young billionaire reflects on how to make the world a better place by directing capital to areas that need it, why not add another section to the Internal Revenue Code? If it works society will have gotten quite a bang for his activist bucks.
Kent Hovind’s Hail Mary Pardon Pass
As I write this Kent’s vote fraud video is at 5,500 views. There are a lot of ifs, but if it takes off and gets some love from people actually connected with Trump, who knows? President Trump has been complaining about how mean the IRS has been to him, why not do something for Doctor Hovind?
PPP IRS And Tax Deductions – Is Resistance Futile?
Originally published on Forbes.com. A Treasury news release makes it clear that the IRS is holding firm to its negative view on deducting expenses paid by forgivable...
IRS Threatens 75% Fraud Penalty For Investors In Syndicated Conservation Easements
The answer is the same for both types of partnerships. The fraud penalty is determined at the partnership level. In order to assert the fraud penalty the IRS must prove “by clear and convincing evidence, the elements of the fraud penalty based on the partnership-level conduct and intent of the manager(s) of the partnership”. What the investor partnersh though is really not relevant.
Ms. Black makes it clear that there is nothing different about SCEs in this regard compared to other partnerships.
Coca-Cola And Amazon In Tax Court – Where Are The Intangibles?
Why are the supply points, engaged as they are in routine contract manufacturing, the most profitable food and beverage companies in the world? And why does their profitability dwarf that of TCCC, which owns the intangibles upon which the Company’s profitability depends?