Most Recent Posts
Expenses Paid with a Forgiven PPP Loan are Deductible, IRS is Wrong
No court has ever ruled, nor would it ever rule, that cancellation of debt that is claimed to be non-taxable pursuant to existing exclusions, whether that be due to insolvency or bankruptcy under Section 108 or pursuant to Section 1106 of the CARES Act, somehow requires a taxpayer to amend prior-year returns to remove deductions attributable to the non-taxable cancellation of debt.
A Defense Of The Break Republicans Snuck Into The CARES Act
The coverage on this move, which apparently was a fast one in that the voting came before the scoring, has been negative. There is a lonely voice out there crying that rather than fooling with the effective date, 461(l) should have been retroactively repealed as it is poor tax policy and unfair.
Judge Urges Prison Furlough For Author Of “Biggest Tax Fraud Ever”
With many well-heeled felons like Zukerman able to afford the costs of getting a motion for early release before a court, one hopes that the BOP takes a proactive approach with other inmates who do not have the same resources. While the pandemic should not necessarily amount to a get out of jail card for all felons, it should not amount to a pass for only those who can pay for their freedom
IRS Moves To Virtual Settlement Meetings
A lot of people represent themselves in Tax Court. That it is why you don’t need to watch situation comedies or reality TV if you read Tax Court decisions like I do. Some of them, particularly lawyers and engineers, represent themselves because they are so smart. That often does not end well. Others do so because they can’t afford representation or the stakes are too low to make it worthwhile.
IRS Rains On The Paycheck Protection Parade
PPP can still be a really good deal and I think it would be worth testing the IRS on this. I am close to certain that more than a few taxpayers will take the deduction anyway and the matter will end up in the courts unless Congress quickly clarifies this one way or the other.
Who Gets The Million Plus Stimulus Checks?
One of Terry’s fascinating theories is that President Trump turns down his salary so that he can continue to be treated as being a real estate professional. Terry also thinks that the President’s switch to Florida residence (which I predicted-not bragging, just saying) was motivated by the state income tax headaches that 461(l) has indirectly created for people with enterprises of his complexity.
Banks Keeping Paycheck Protection Fees Meant For Others
The Paycheck Protection Program was designed to not cost the borrowers anything if they used the money correctly. So banks were given a fee as high as 5% paid by SBA,...
Deep Pockets Need To Return Paycheck Protection Money
There has been an uproar about some of the companies that have taken the money and now we have new guidance from the ever growing FAQ on the Treasury website. In a few years we may be reading a lot about FAQ 31 litigation as not everyone will attend to or be intimidated by the latest guidance. Here is it in full.
“Question: Do businesses owned by large companies with adequate sources of liquidity to support the business’s ongoing operations qualify for a PPP loan?
Paycheck Protection Program Gets Big Boost
There is still no clarification on whether you will be able to deduct payments that are made with loan proceeds that are forgiven. We still don’t know what happens if you have not spent all the money by June 30. And maybe it would be good if there was more of an idea about how uncertain we need to be in order to qualify. For example, should a company with a large stash of cash be allowed in before they spend their rainy day fund?
Florida Firm Passes On Paycheck Protection Program
In advance, I figured that the wealthy who had CPA’s, tax advisors, banking relationships, and are organized would be first in and would obtain a good chunk of the money intended for those who really needed it. Anticipating that is why I decided not to take the money even though I had all of the paperwork ready to send.
My business is a small business largely dependent on contingent fee real estate commissions. Those will dry up and I could have used the money. I just figured there were folks who would need it more than me. Personal responsibility as a citizen is still important at the micro-level. Bad micro-decisions lead to macro problems.