Tax cases are interesting in that they apply a fairly well-developed set of rules to varying fact patterns. These varying fact patterns can result in surprising, and often unintended, consequences. The more complex the tax law in question, the more likely it is that the outcome will be something other than what Congress may have……
TX-LW Blogs
Galveston County Reports its First COVID-Related Death in a Child
Kali Cook, a 4-year-old Galveston County girl, was running around her Bacliff home Monday, gleefully batting the fake red eyelashes her grandmother had given her for Labor Day. By 2 a.m., she had a fever. By morning she was gone. The 4-year old died of COVID-19 in her sleep Tuesday at 7 a.m., her mother…
IRS Lien on Trust Assets
As long as the government tries to collect taxes, there will be taxpayers who try to find ways to not pay the taxes. These tax payment avoidance options often involve co-ownership of property or, in many cases, trusts. The recent United States v. Simones, No. 1:20-cv-00795-PJK-SCY (D.N.M. 2021) case shows how the IRS is able……
Qualifying for Section 1244 Stock Losses
The Tax Cuts & Jobs Act of 2017 changed the choice of entity decision quite a bit. It affords corporate taxpayers the benefit of the lower flat 21 percent tax rate. It provides non-corporate businesses a 20% qualified business income deduction. There were other changes too. This is in addition to the existing tax rules……
What Does the FDA’s Full Approval of the Pfizer Vaccine Mean?
The FDA announced on Monday the full approval of the Pfizer vaccine for those 16 and older. That means the vaccine has now undergone extensive review over a substantial period of time —more than six months —to ensure long-term safety, said Dr. Prathit Kulkarni, with infectious diseases at Baylor College of Medicine. A fully approved…
Defense Contractor Able to Exclude Foreign Income
United States citizens pay tax on their worldwide income. This general rule can result in double taxation–with the United States imposing tax on the same income that was already taxed by a foreign government. The United States has tax treaties with many countries that help avoid this type of double taxation. The United States also……
Tax Deductions Associated With “Other Income”
The IRS was recently given a significant increase in its budget. Its request for more money was premised on the need to hire more IRS revenue agents to audit more non-compliant tax returns. While the IRS has in fact reduced its headcount significantly, it has also benefitted from recent tax law changes. Some of these……
Only 27 ICU Beds Left in Houston’s Trauma Service Area
More than 10,000 Texans are hospitalized for COVID-19, according to data released by the Texas Department of State Health Services Tuesday afternoon. According to Tuesday’s report, 10,041 people were hospitalized with COVID-19 across the state of Texas on Monday, the highest rate since Feb. 4, as the delta variant continues to dominate new COVID-19 infections.…
Tax Consequences of a Loan vs. Capital Contribution
Taxpayers often structure their affairs to their advantage. Our legal system and even our tax laws allow for this. With many transactions, one way this is done is structuring transfers as either loans or capital contributions. The tax ramifications for the transfers can vary widely based on this type of broad classification. This distinction is……