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
Sec. 6015 Does Not Preempt State Community Property Law for Refund Purposes
Article:
The Ninth Circuit affirmed the Tax Court and held that Sec. 6015 does not preempt state community property law with respect to an innocent spouse’s right to a refund.
Published on March 11, 2011
S Corporation Shareholder Loans A Cautionary Tale
Article:
A practitioner should take special care in advising clients on shareholder loans to an S corporation. Repayment of the loans by the corporation has the potential to generate unexpected taxable income to the shareholder.
Published on March 11, 2011
S Corporation Sale of Assets Followed by a Liquidation
Article:
This item focuses on the specific tax implications to the seller of the sale of an S corporation's assets followed by a liquidation or a deemed asset sale followed by a liquidation.
Published on March 11, 2011
Requesting 9100 Relief
Article:
Certain extension and administrative relief options exist if the taxpayer can obtain "9100 relief" under Regs. Secs. 301.9100-1 through -3.
Published on March 11, 2011
Prop. Regs. Govern Charitable Contribution Substantiation and Reporting
Article:
Tthe IRS issued proposed regulations that would change the rules regarding substantiation and reporting of charitable contributions.
Published on March 11, 2011
New Developments in the Texas Franchise Tax
Article:
On May 18, 2006, Texas governor Rick Perry signed legislation that completely revamped the Texas franchise tax law (2006 TX H.B. 3).
Published on March 11, 2011
Power of Attorney Limited vs. Full
Article:
While checking the third-party designee box on the return is an easy way for a taxpayer to authorize another person to act on his or her behalf, doing so only gives that person limited authority (compared to a traditional power of attorney) to act on the taxpayer’s behalf, and the
Published on March 11, 2011
Housing Act Contains Tax Provisions
Article:
On July 30, 2008, the president signed into law the Housing Assistance Tax Act of 2008, containing tax provisions affecting homeowners and first-time homebuyers, as well as changes to the rules governing the low-income housing credit, tax-exempt bonds, and the alternative minimum tax (AMT).
Published on March 11, 2011