TaxClinic

Practical Advice
on Current Issues

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Editor:
Kevin F. Reilly, J.D., CPA
PKF Witt Mares
Fairfax, VA

IN THIS DEPARTMENT

Corporations & Shareholders

Conversion of C corporation into an LLC

Tax planning for small business stock

Estates, Trusts & Gifts

Bona fide sales in the estate environment

Intentionally defective grantor trusts

Sec. 2632 prop. regs. on electing out of deemed GST allocations

Foreign Income & Taxpayers

Foreign partnerships in estate tax planning for NRAs

Gains & Losses

At-risk final regs. on “disqualifying interests”

LLCs & LLPs

Holding period of partnership/LLC interests

Partners & Partnerships

IRS can assess partnership, but collect from partners

S Corporations

IRS guidance for post-reorganization QSub terminations

Reducing BIG for QSub stock

If you would like additional information about these items, contact Mr. Reilly at (703) 385-8809 or kreilly@pkfwittmares.com.

Unless otherwise indicated, contributors are members of PKF North American Network