Sec. 1031 Related-Party Exchanges and Basis Shifting

Article:  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 April 17, 2012

Like-Kind Exchanges of Partnership Properties

Article:  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 May 03, 2010

Reorganizations and Tax Attribute Survival

Article:  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

Circular Like-Kind Exchange Disallowed

Article:  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 January 28, 2011

Planning for Current Distributions from an LLC

Article:  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 May 10, 2010

Tax Consequences of Transaction Costs

Article:  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 October 04, 2011

New Rules Seek to Reduce Tax Advantages of Converting Second Home to Principal Residence

Article:  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 May 03, 2010

Individual Taxation Filing Season Update

Article:  This article covers recent significant developments affecting taxation of individuals, including cases, regulations, and legislative changes, and important information for the upcoming filing season.
Published on April 21, 2010

Individual Taxation Developments

Article:  This article covers recent developments affecting individual taxation. The items are arranged in Code section order
Published on March 18, 2013

Individual Tax Update

Article:  This article covers recent developments affecting individual taxation.
Published on November 30, 2012

Individual Taxation Report

Article:  This article covers recent developments affecting taxation of individuals, including legislation, regulations, and IRS guidance.
Published on May 10, 2010

Reporting Dilemma Personal Use of Rental Properties

Article:  Properly apportioning real estate expenses between personal and rental use presents several challenges.
Published on April 30, 2012

Individual Taxation Report

Article:  This article covers recent significant developments affecting taxation of individuals, including cases, IRS guidance, and legislative changes.
Published on January 28, 2011

Individual Taxation Digest of Recent Developments

Article:  This article covers recent significant developments affecting taxation of individuals, including legislative changes, cases, regulations, and other IRS guidance.
Published on January 28, 2011

Edges of Acceptable Tax Planning

Article:  The 11th Circuit affirmed the application of section 1031(f)(4) to a like-kind exchange that was structured by a corporation to avoid the purposes of the related party rule of section 1031(f). Ocmulgee Fields, Inc. v. CIR, No. 967...
Published on January 28, 2011