The Tax Adviser August 2009
Publication:
Published on March 11, 2013
Two Recent Revenue Rulings Clarify Tax Treatment of Life Settlements
Article:
The IRS issued two revenue rulings discussing the taxation of life settlement transactions. Rev. Rul. 2009- 13 clarifies the tax implications of the surrender or sale of a life insurance policy by the original policyholder, while Rev. Rul. 2009-14 discusses the tax ramifications of certain transactions to an investor who
Published on July 13, 2012
Restructuring Partnership Debt May Create Unexpected Results
Article:
A partnership or an LLC taxed as a partnership contemplating a debt restructuring should carefully consider the tax effects of Sec. 108.
Published on July 13, 2012
Deducting Ponzi Scheme Losses Practical Issues
Article:
In March 2009, the IRS issued Rev. Rul. 2009-9 and Rev. Proc. 2009-20, which provided guidance on the tax treatment of theft losses from Ponzi-type schemes.
Published on July 13, 2012
Service Learning and Tax More Than VITA
Article:
This column provides readers with some thoughts for integrating service learning using tax issues as the content platform. The column describes the projects used by the author and some additional thoughts for expanding the scope of tax-based service learning projects beyond VITA.
Published on January 28, 2011
Avoiding S Corporation Debt Obligations That Are a Second Class of Stock
Article:
Under certain circumstances, debt owed by an S corporation to one or more shareholders will be a second class of stock.
Published on January 28, 2011
Ninth Circuit Awards Litigation Costs Paid by Third Party
Article:
The Ninth Circuit reversed the Tax Court and held that a taxpayer could “incur” attorneys’ fees initially paid by a third party for purposes of an award of litigation costs under Sec. 7430.
Published on January 28, 2011
Tax Planning for Troubled Debt
Article:
Today’s volatile real estate environment presents interesting opportunities for investors and developers to alter the terms of their debts in ways that may pay off if they can retain control of their projects.
Published on January 28, 2011
Two Courts Address Tax Shelter Exception to Tax Practitioner Privilege
Article:
The Tax Court and the Seventh Circuit recently decided cases dealing with the tax practitioner/client privilege under Sec. 7525.
Published on January 28, 2011
Treasury Provides Roadmap for Shift in Tax Burden
Article:
On May 11, 2009, Treasury released General Explanations of the Administration’s Fiscal Year 2010 Revenue Proposals.
Published on January 28, 2011
Tax Preparer Penalties Who Is a Preparer
Article:
Recent changes to the tax preparer penalty statute expose signing and nonsigning tax preparers of income, estate, gift, and certain information returns to higher monetary penalties and make it vital that they understand who is a preparer under the new rules.
Published on January 28, 2011
Supreme Court Grants Cert. in Bilski Case
Article:
The Supreme Court granted a writ of certiorari in the case of Bilski v. Doll; the Court agreed to review the Federal Circuit’s earlier decision in the case and possibly put to rest the question of when business methods are eligible for patent protection.
Published on January 28, 2011
Ninth Circuit Rules on Tax Court Jurisdiction in Partnership Cases
Article:
The Ninth Circuit has held in a group of consolidated cases that the Tax Court has jurisdiction to decide in partner-level proceedings whether a partnership’s transactions were tax motivated.
Published on January 28, 2011
The Long Arm of Community Property Laws
Article:
The impact of community property laws on tax issues is vast and complex. Advisers must be mindful of this when learning about their clients, whose geographical history may be as important to consider as their financial and business background.
Published on January 28, 2011
Exclusion for Income from Discharge of Indebtedness Mortgage Debt Forgiveness
Article:
The Mortgage Forgiveness Debt Relief Act of 2007 provides an exclusion from income for the discharge of indebtedness (DOI) on a qualified principal residence. The exclusion is effective for home mortgage debt discharged between January 1, 2007, and December 31, 2012.
Published on January 28, 2011