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Income Taxes › Internal Revenue Service › Promissory Notes

Income taxes are taxes that are collected on the individual earnings of persons or entities. Depending on the jurisdiction, income taxes are calculated and collected in a variety of ways. Some tax systems collect... more +
Income taxes are taxes that are collected on the individual earnings of persons or entities. Depending on the jurisdiction, income taxes are calculated and collected in a variety of ways. Some tax systems collect income taxes based on a progressive scheme, while others may utilize a proportional or regressive framework. less -
Fox Rothschild LLP

Partnership Interest Sale Inventory Gain is Not U.S. Source Income

Fox Rothschild LLP on

On July 23, 2024, the U.S. Court of Appeals for the D.C. Circuit reversed the U.S. Tax Court in holding that inventory gain recognized by a nonresident alien individual partner on the sale of her interest in a U.S....more

Rivkin Radler LLP

Partnership Transactions Lacking Economic Substance or Business Purpose: Investor Beware

Rivkin Radler LLP on

Assume that X and Y agree to the following: X will transfer ownership of Prop to Y, and Y will transfer cash to X. What just happened? Obviously, X has sold Prop to Y. If the amount of cash that X receives is greater than...more

Rivkin Radler LLP

Cash In Hand, Tax Deferral, Monetized Installment Sales: No, You Can’t Have It All

Rivkin Radler LLP on

Ask the owner of a closely held business to describe their most recently recurring nightmare and you are likely to get an earful regarding the prospect of an increased federal income tax on their profits, an increased federal...more

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