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Internal Revenue Service Business Losses

The United States Internal Revenue Service is a bureau of the United States Department of the Treasury. The IRS is charged with collecting revenue and enforcing the Internal Revenue Code.  
Foster Garvey PC

A Journey Through Subchapter S / A Review of The Not So Obvious & The Many Traps That Exist For The Unwary: Part XI – A...

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In this Part XI of my multi-part series on some of the not-so-obvious aspects of S corporations, I explore a topic that should be obvious but which appears to be ignored by many taxpayers and their tax advisers – accurate...more

Holland & Knight LLP

IRS Targets Owners of Professional Sports Franchises Regarding Tax Reporting

Holland & Knight LLP on

Basketball just wrapped up its season and hockey is in the last period of its season, but there is no summer vacation for the IRS Large Business and International (LB&I) division. The IRS recently announced a new enforcement...more

Foster Garvey PC

A Journey Through Subchapter S / A Review of The Not So Obvious & The Many Traps That Exist For The Unwary: Part IV – Suspended...

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This fourth installment of my multi-part series on Subchapter S is focused on suspended losses of an S corporation. While the rules seem straightforward, their application can be tricky, especially given legislative changes...more

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 on Related Party Sales – The IRS Provides Some Clarification

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Few individual owners of a closely held business would be surprised if you explained to them that the IRS and the Federal courts generally will subject many transactions between certain “related” persons to heightened...more

Allen Barron, Inc.

Are There Strategies to Avoid an IRS Audit?

Allen Barron, Inc. on

Are there strategies to avoid an IRS audit? What are some of the known risks for triggering an IRS audit? What should you do if you have are concerned about the information provided a previous tax return? Is there a way to...more

Rivkin Radler LLP

Partnership Losses But No Outside Basis? Too Bad

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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

Eversheds Sutherland (US) LLP

Wrong place, right time: IRS questions COVID-19 disaster loss for CFC worthless stock

During the COVID-19 federally declared disaster, companies scrambled to come up with tax strategies that could help to curb economic losses resulting from the COVID-19 pandemic. The section 165(i) acceleration provision for...more

Rivkin Radler LLP

Trump’s Returns and Congress – Lessons, Next Steps?

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Last Friday, December 30, 2022, during the final hours of the 117th Session of Congress, the House Ways and Means Committee – through which all tax legislation passes – released redacted versions of six years of Mr. Trump’s...more

Kohrman Jackson & Krantz LLP

2021 Tax Changes For Businesses: The Not So Good, The Bad And The Ugly

As small and mid-size business owners move toward the federal tax filing deadline in this new year, they need to be aware of certain changes in the federal income tax area. A short listing of the highlights (more...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

Foster Garvey PC

House of Representatives 5376: Current Tax Legislation Pending in the U.S. House of Representatives

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...The federal tax laws are certainly about to change. With the need to raise revenue as a top priority for the Biden Administration, everyone is expecting dramatic changes to the Internal Revenue Code. Tax legislation is...more

Rivkin Radler LLP

Step Transaction Or Substance Over Form? Loss Disallowance In Any Case

Rivkin Radler LLP on

The Dog Days- I’ve never much cared for the month of August. In New York, at least for me, the eighth month of the year – named by the Roman Emperor, Augustus, to honor himself – evokes memories of very warm, very humid...more

Rivkin Radler LLP

“Opaque Income Sources” + “Tax Gap” = More Enforcement + Tax Hikes = Anyone’s Guess

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Tax Gap- In a report released last week, the U.S. Treasury Department explained that the so-called “tax gap” – i.e., the difference between the amount of federal income taxes owed by taxpayers for a taxable year and the...more

Eversheds Sutherland (US) LLP

State of play: A May methods update 

At last week’s ABA May Tax Meeting, government attorneys from both the Internal Revenue Service National Office Income Tax & Accounting division (IT&A) and the Department of the Treasury provided updates to taxpayers and...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

Farrell Fritz, P.C.

Turning A Hobby Into A Business And Into Tax Trouble

Farrell Fritz, P.C. on

“Find a Hobby”- Over the years, many colleagues, friends and family who have observed my work habits have suggested, with the best of intentions, that I find a “hobby,” by which they mean something other than a...more

Troutman Pepper

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

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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

McGlinchey Stafford

What does the CARES Act mean for net operating losses and non-corporate business losses?

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The CARES Act temporarily suspends retroactively changes made to the treatment of net operating losses by the 2017 Tax Cuts and Jobs Act (the “2017 Tax Act”). It also suspends retroactively the limitation on excess business...more

Lowndes

$2.2 Trillion Stimulus Bill Includes Big Benefit For Real Estate Investors and Other Taxpayers With Excess Business Losses

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The Coronavirus Aid, Relief, and Economic Security Act (CARES) Act was passed by Congress and is expected to be signed into law by President Trump. This $2.2 trillion stimulus bill contains an important tax benefit that so...more

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