Year-End Individual Taxation Report
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
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
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
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
...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
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
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
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
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
Health Care Legislation Requires New Planning Strategies
Two areas that practitioners should examine for opportunities to reduce the impact of Medicare tax increases on their clients are the structure of privately owned businesses and holdings in passive investment activities
Published on September 01, 2010