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Fair Market Value Tax Planning Internal Revenue Service

Seward & Kissel LLP

Final Tax Rules and Transitional Guidance for Broker Reporting

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The Internal Revenue Service (“IRS”) recently finalized Treasury Regulations (the “Final Regulations”) and published two notices and a Revenue Procedure (the “Transitional Guidance”) for broker reporting of certain...more

DarrowEverett LLP

Maximizing Value: The Art of Purchase Price Allocation in Real Estate Deals

DarrowEverett LLP on

When a business is sold, the most important overall aspect of negotiations between a cautious buyer and determined seller may be due to the agreed-upon purchase price for the business. However, when the buyer is purchasing...more

Polsinelli

Bare Knuckle Conservation Easement Brawl Leaves Participants in Limbo

Polsinelli on

Two recent tax court cases paint an ominous picture for professionals and investors who participated in listed syndicated conservation easement transactions. Coming on the heels of the Fisher conviction and his lengthy...more

Troutman Pepper

Rolling Over and Section 704(c); What’s the Big Deal? — Part 4: The Remedial Method

Troutman Pepper on

In our continuing series on Section 704(c) of the Internal Revenue Code (the Code) we discuss the application of the remedial method to correct for distortions caused by the ceiling rule. As previously discussed, when the tax...more

Troutman Pepper

Rolling Over and Section 704(c); What's the Big Deal? — Part 3: The Traditional Method With Curative Allocations

Troutman Pepper on

Continuing with our series on the implications of the application of Section 704(c), the below discussion addresses the use of the traditional method with curative allocations. In Part 1 [insert link] we gave a broad overview...more

Polsinelli

Conservation Easements: Palpable Fraud or Honest Mistakes? A Federal Jury Returns a Split Verdict

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On September 22, 2023 a federal jury convicted two promoters, CPA Jack Fisher and attorney James Sinnott, in the Department of Justice’s (“DOJ”) first criminal trial over allegedly abusive syndicated conservation easements...more

Lathrop GPM

Valuable Lessons in Charitable Deductions

Lathrop GPM on

A recent Tax Court case provides important guidance for donors and charities making and negotiating gifts of appreciated property. While generally donors who donate appreciated property to a public charity do not recognize...more

Freeman Law

Tax Court in Brief | Cattail Holdings, LLC v. Comm’r | Conservation Easement “Protected in Perpetuity” and Supervisory Approval of...

Freeman Law on

Summary: In September 2016 Dolomite Holdings 251, LLC (Dolomite), acquired a 723-acre tract of land in Virginia. On November 28, 2017, Dolomite contributed 207 acres of this tract (Property) to Cattail in exchange for a 100%...more

Adler Pollock & Sheehan P.C.

Estate Planning Pitfall: You Sell Real Estate for $1

Someone may have told you a story along these lines: Years ago, my grandfather bought land along the shore in (fill in a desirable resort area) for $1,000. He built a vacation home on the property for $50,000 and his family...more

Pullman & Comley - For What It May Be Worth

Valuation of Conservation Easement Determined by U.S. Tax Court

A trial before the United States Tax Court recently determined the value of a conservation easement imposed on a Georgia golf course which was being contested by the Internal Revenue Service. Relying on the “before and after”...more

Opportune LLP

Gift & Estate Tax Valuation: 5 Things To Remember

Opportune LLP on

Here are five things to remember when performing the valuation of shares of a closely held entity for gift and estate tax reporting...more

Farrell Fritz, P.C.

Responding To The Democratic Party’s Tax Plans

Farrell Fritz, P.C. on

The Convention- The Democratic Party’s “virtual” convention last week seems to have gone pretty well. All the stars of the Party’s firmament were on hand and spoke in “virtually” one voice in their assessment of the...more

Orrick, Herrington & Sutcliffe LLP

Tax Relief for Replacing LIBOR in Tax-Exempt Debt and Swaps

Many tax-exempt bonds and related hedges, such as interest rate swaps ("Exempt Instruments"), use a LIBOR-based interest rate. LIBOR is going away, and existing Exempt Instruments are going to have to be modified to replace...more

Burr & Forman

Cryptocurrency Tax Guidance Expected Soon

Burr & Forman on

The Internal Revenue Service (“IRS”) will be releasing guidance on the tax treatment and reporting requirements of “virtual currencies” (i.e., cryptocurrencies) very soon, according to Internal Revenue Service Commissioner...more

Foodman CPAs & Advisors

Lo que sabemos sobre el Cumplimiento Crypto y los impuestos federales de los EE. UU.

La última Notificación emitida por el IRS sobre Criptomoneda fue el Aviso 2014-21 publicado el 25 de Marzo del 2014 que brinda orientación en forma de respuestas a preguntas frecuentes (“Frequently Asked Questions”). ...more

Foodman CPAs & Advisors

Many are now looking for IRS Guidance on Virtual Currency

Foodman CPAs & Advisors on

Due to its unprecedented level of value appreciation, Bitcoin investors, consumers and businesses are looking for IRS Guidance. IRS recognizes that “virtual currency” may be used to pay for goods or services, or be held for...more

Burns & Levinson LLP

IRS Proposes Regulations That Will Eliminate Most Valuation Discounts on Family-Owned Entities

Burns & Levinson LLP on

On August 2, 2016, the IRS issued proposed regulations that would eliminate or limit the use of certain valuation discounts regularly applied when valuing interests in family-owned entities for gift and estate tax purposes. ...more

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