A tax attorney might say that you should never go into an iffy transaction naked. This refers to a tax position that covers a real or perceived tax liability from a transaction. This is a corporate tax concept. Larger corporations often have a longer view when it comes to business tax planning. Given their time……
Category: Tax Law
Contribution to Corporation, then Sale of the Corporation
Most income tax planning involves questions about income, deductions or credits, character, or timing, or some combination of these questions. When viewed from these categories, even simple transactions can present tax planning opportunities. The contribution of property to a corporation by its shareholder is an example. A contribution triggers taxable income to the shareholder. Our……
Charter Boat Expenses are Miscellaneous Itemized Deductions
We live in a complex society. Even common activities can be exceedingly complex. Take a charter boat operation, for example. One has to consider the various laws for registering the boat; laws that dictate where and when the boat can operate; the laws governing the crew and its activities; and financing and loan and insurance……
Tax Planning for Demolished Buildings
It is often said that bad things happen in threes. This is a nice way of saying that too many bad things have happened in quick succession, so hopefully, the person will not suffer further calamities in the short term. Tax attorneys view calamities in terms of tax losses and/or net operating losses. As tax……
Factors Showing Innocent Spouse Relief
The IRS has wide discretion in how it administers our tax laws. This discretion is power in its purest sense. This power can be wielded to destroy hard-won reputations, careers, and fortunes and it can even cost individuals their freedom. These powers can come from ambiguities in our laws. They can come from restrictions in……
Rental Tax Losses for Those With Irregular Hours
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……
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……
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……