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    Year-End Individual Taxation Report

    Article This article covers developments from the past year affecting taxation of individuals, including last year’s tax relief, health care, and small business legislation, regulations, cases, and IRS guidance.
    Published on August 24, 2012

    Maximizing the Use of the Special $25,000 Rental Real Estate Loss Allowance

    Article Even though rental income or loss is generally passive, a special rule allows qualifying individuals and estates to offset up to $25,000 of nonpassive income with rental real estate losses and credits. This column describes the criteria...
    Published on November 01, 2010

    Interaction of the Subpart F Dual-Character Property and Majority-Use Rules

    Article When a controlled foreign corporation (CFC) sells property used in its active business, any gain generally is not treated as subpart F income includible in its U.S. shareholders’ taxable income
    Published on July 25, 2013

    Changing Level of Participation in an S Corporation for Tax Planning Purposes

    Article A shareholder materially participates in an S corporation if the shareholder or the shareholder’s spouse is involved in the corporation’s trade or business on a regular, continuous, and substantial basis. This column discusses three tests that practitioners are likely to encounter when dealing with S corporation shareholders.
    Published on January 13, 2012

    Disposing of an Activity to Release Suspended Passive Losses

    Article ...disposes of the particular activity that generated the losses, (2) generates net passive activity income in the case of a personal service corporation, or (3) generates net passive activity income or net active income in the
    Published on May 21, 2010

    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

    Ordinary Worthless Stock Deductions Characterizing Subsidiary Receipts

    Article An ordinary loss deduction for worthless stock of an affiliated operating subsidiary generally is permitted as long as more than 90% of the subsidiary’s gross receipts are from active operating income. This item discusses the difficulty of determining whether a subsidiary’s gross receipts qualify as active operating income for this purpose
    Published on October 04, 2011

    Limited Partners and Material Participation A Tax Planning Opportunity

    Article The IRS issued proposed regulations that seek to redefine the term “limited partner” for purposes of the passive activity rules of Sec. 469
    Published on March 18, 2013

    Tiered Partnerships Will Net Investment Income Tax and Proposals to Change Taxation of Carried Interests Wreak Havoc

    Article Tiered partnerships could become subject to ordinary income tax treatment on many forms of revenue that had previously enjoyed a lower capital gain tax rate.
    Published on July 31, 2013

    Applying the New Net Investment Income Tax to Trusts and Estates

    Article This article discusses how the new 3.8% net investment tax applies to trusts and estates.
    Published on April 30, 2013

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