News & Analysis as of

Business Losses Tax Court

Rivkin Radler LLP

Intercompany Loan Treated As Constructive Distribution and Contribution

Rivkin Radler LLP on

Heads I Win, . . . - When closely held corporations that are under common control engage in any intercompany transaction, it is prudent for the corporations and their shareholders to ensure that the transaction is being...more

Rivkin Radler LLP

Partnership Losses But No Outside Basis? Too Bad

Rivkin Radler LLP on

Losses Weren’t Always Bad- Most tax advisers are aware that, prior to the Tax Reform Act of 1986 (the “TRA”),[i] the Code placed few limitations on the ability of an individual taxpayer to use deductions from a particular...more

Proskauer Rose LLP

UK Tax Round Up - January 2022

Proskauer Rose LLP on

UK Case Law Developments - Contributions to remuneration trust scheme not tax deductible - In Strategic Branding Ltd v HMRC, the First-tier Tribunal (FTT) held that sums contributed by the taxpayer company to a...more

Gray Reed

Taxpayer’s Testimony on Businesses Losses Defeats IRS Arguments and Penalties

Gray Reed on

Starting any business has risk, and most businesses take time to become profitable. Unfortunately, the IRS sees multiple years of losses from a business as a red-flag that usually results in further scrutiny. That scrutiny...more

Farrell Fritz, P.C.

How Dealings Between Related Parties Doomed A Captive Insurer

Farrell Fritz, P.C. on

Insurance: What is it? How does it work? Assume that Acme Co is paying premiums for commercial insurance coverage to protect itself from economic losses that may arise out of various events. These premiums are deductible...more

Burr & Forman

Cannabis Business Takes Position That § 280E Is Unconstitutional – And It’s Like a Grocery Store For Adults

Burr & Forman on

Cannabis (or marijuana) dispensaries have long stated that they are subjected to harsher tax consequences under the Internal Revenue Code (“IRC” or “Code”) than their “legal” counterparts. Specifically, they have argued, in...more

Troutman Pepper

When Does a Loan Guarantee Provide Amounts at Risk - Tax Update, Volume 2020, Issue 3

Troutman Pepper on

In Bordelon v. Commissioner, the Tax Court addressed the circumstances under which an individual’s personal guarantee of a loan to his single-member LLC established sufficient amounts at risk to enable him to claim more than...more

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