Sec. 1031 Related-Party Exchanges and Basis Shifting
The Code provides a number of related-party exceptions designed to circumvent certain abuses, the most prevalent of which is basis shifting. This item discusses ways that practitioners can avoid basis-shifting problems.
Published on October 01, 2011
Like-Kind Exchanges of Partnership Properties
A partnership can distribute real property to its partners so that the partners can exchange the property in a Sec. 1031 like-kind exchange; if the exchange is properly structured, some of the partners can trade their interests in the property distributed in Sec. 1031 exchanges and...
Published on December 01, 2008
Like-Kind Exchange Rules Continued Evolution
For many years, taxpayers have been able to defer recognition of gain on the disposition of assets by engaging in Sec. 1031 like-kind exchanges. Consequently, many questions and issues surrounding these transactions have been addressed, but many cases and rulings continue to arise each year. This article analyzes these cases
Published on July 01, 2014
Circular Like-Kind Exchange Disallowed
The Tax Court disallowed tax-free treatment for a like-kind exchange transaction in which the taxpayer exchanged properties with a related entity
Published on June 01, 2009
Reorganizations and Tax Attribute Survival
Whether tax attributes will survive corporate tax reorganizations often becomes a critical consideration in assessing the ramifications of a proposed transaction. This item discusses issues surrounding these reorganizations and emphasizes the need for practitioners to have a good foundational understanding of the relevant rules.
Published on December 01, 2010
New Rules Seek to Reduce Tax Advantages of Converting Second Home to Principal Residence
Beginning January 1, 2009, the full $250,000/$500,000 exclusion under Sec. 121 will no longer be available on the sale of a taxpayer's principal residence if the residence was subject to nonqualifying use prior to its ultimate disposition.
Published on December 01, 2008
Planning for Current Distributions from an LLC
LLC distributions most frequently occur when an LLC distributes operating cashflow or refinancing proceeds or liquidates a member’s interests. But distributions can also be used to accomplish the LLC’s tax planning goals.
Published on February 01, 2008
Tax Consequences of Transaction Costs
This article discusses the tax consequences of transaction costs in four settings: in general, when acquiring or producing tangible assets, when acquiring or creating intangible assets, and when acquiring a business.
Published on June 01, 2011
Individual Taxation Report
This article covers recent developments affecting taxation of individuals, including legislation, regulations, and IRS guidance.
Published on September 01, 2008
Individual Taxation Digest of Recent Developments
This article covers recent significant developments affecting taxation of individuals, including legislative changes, cases, regulations, and other IRS guidance.
Published on March 01, 2010