Ninth Circuit Affirms Transferred Residential Property Must Be Included in Gross Estate
Article:
The Ninth Circuit ruled that the full fair market value of residential property must be included in the decedent’s gross estate, finding that the decedent retained income and economic enjoyment from the property and that the inter vivos transfer of the property was not a bona fide sale for adequate
Published on March 18, 2013
Current Corporate Income Tax Developments (Part II) - 2008
Article:
This article covers some of the more important developments in apportionment formulas, unitary groups/filing methods, administration, flowthrough entities, and other significant corporate state tax issues.
Published on January 22, 2013
Using Serial IRAs to Stretch the 60-Day Rule for IRA Rollovers
Article:
This item outlines steps that can be taken to stretch the 60-day IRA rollover window to 300 days without violating the 12-month rule.
Published on September 06, 2012
Taxation of Exchange Traded Notes
Article:
This item provides an overview of the structure of an exchange traded note and the current tax treatment of these instruments and an update on some of the guidance that has been issued related to taxation of ETNs
Published on July 13, 2012
Avoiding the Self-Rental Trap
Article:
This item gives a general background of the passive activity rules and the self-rental provision and addresses the consequences of a sale of an operating company when the self-rental property is retained.
Published on July 13, 2012
A Practical Guide to the Tax Issues of Investing in Master Limited Partnerships
Article:
The tax reporting related to publicly traded partnerships has become an increasingly significant issue facing the tax practitioner community.
Published on July 13, 2012
Adapting to the United Kingdoms New Remittance Basis Rules
Article:
There have recently been some radical changes in the taxation of certain taxpayers in the United Kingdom.
Published on July 13, 2012
Benefiting from a Fiscal Tax Year
Article:
The use of a 52-53-week year can provide significant tax planning opportunities for a C corporation and its shareholders.
Published on November 07, 2011
Using Debt to Leverage a Taxable Gift to a QPRT
Article:
A qualified personal residence trust is a trust created to own a personal residence of the grantor for the benefit of the grantor's spouse, children, or charity. The grantor makes a gift of a personal residence into the trust while retaining a right to occupy the residence for a term
Published on March 11, 2011
Vacation Property Rental and Resale
Article:
The vacation home rules have always been confusing, and with the enactment of Sec. 121(b)(4) they have become more convoluted for clients who convert a vacation home to a principal residence.
Published on March 11, 2011
Treatment of Investment Interest Expense Allocable to Partnerships Trading Activity
Article:
IRS rulings confirm the proper tax treatment of investment interest expense allocable to a partnership's trading activity
Published on March 11, 2011
The New Student Tax
Article:
The Internal Revenue Code contains a number of tax incentives to encourage college attendance. However, it also contains one “student tax” disincentive.
Published on March 11, 2011
Termination of a Partnership Interest
Article:
This item explores the two main methods used when terminating a partnership interest: purchase and liquidation.
Published on March 11, 2011
Tax Aspects of an Authors First Book
Article:
The IRS’s longstanding position is that “if an individual writes only one book as a sideline and never revises it, he would not be considered to be ‘regularly engaged’ in an occupation or profession and his royalties therefrom would not be considered net earnings from self-employment.”
Published on March 11, 2011
Selling a Business Substance and Form Really Do Count
Article:
Three concepts regularly come into play when contemplating the sale of a business: noncompete covenants, consulting agreements, and goodwill.
Published on March 11, 2011