Business Law And Transactions
Harvesting Tax Credits Is Legitimate Business for Tax Purposes
If the sole purpose of a partnership is to harvest tax credits, is that a legitimate business for tax purposes? …
Read MorePass-Through Entities in Bankruptcy-Beware of Phantom Income
Recently I discussed the tax issues created by the inadvertent inclusion of partnership tax provisions in an operating agreement for…
Read MoreSelf-Employed and Deducting Car Expenses? – Document or Else!
An internet search of “Schedule C filers” will yield a bevy of sites warning of the increased audit risk and…
Read MoreLegal Fees – Deductible as Ordinary Business Expenses or Capitalized?
This is the question currently on appeal from the Tax Court to the Third Circuit. In Myland, Inc. v. Commissioner…
Read MoreOperating Agreements – One Size Does Not Fit All
A recent private letter ruling highlights the danger of using a form or template blindly. PLR 202219005 involved a limited…
Read MoreNorth Carolina Enacts Pass – Through Entity Tax
Recently the North Carolina General Assembly changed the law to permit pass-through entities (partnerships and s-corporations) to pay entity-level tax,…
Read MoreExcess Compensation and Disguised Dividends – Take Care and Beware!
Yesterday I wrote about a case involving constructive dividends. Today it is disguised dividends. The issue in Clary Hood, Inc.…
Read MoreIpads, iPhones, and Barter Transactions
From the hardly noticed case of Sherwin Community Painters, Inc. v. Commissioner, T.C. Memo. 2022-19, come some interesting tidbits. First,…
Read MoreS-Elections Gone Wrong
The IRS just released four separate Private Letter Rulings (“PLRs”) addressing the inadvertent termination of a taxpayer’s S-election. It is…
Read MoreTreasury Department Issues Proposed Regulations on Disclosure of Beneficial Ownership for Most Business Entities
On December 8, 2021, the Department of Treasury issued a release containing a set of proposed regulations that would implement…
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