It is a basic principle of the income tax that the gain or loss realized by a taxpayer from the conversion of property into cash, or from the exchange of property for other property that differs materially in kind from the...more
The Inflation Reduction Act of 2022 made significant modifications and additions to the energy credit available under Section 48 of the U.S. Internal Revenue Code of 1986, as amended (the “Code” and such credit, the “Section...more
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
In Part 1 of our discussion on Section 704(c) (Part 1) we described the basic idea of how the inherent built-in tax gain or loss on a piece of property contributed to a partnership is allocated to the contributing partner. As...more
The Gift of a Remainder Interest in a Personal Residence Or Farm to Charity is a special technique that fits a small set of charitable donors. For those to whom it does apply, historically low interest rates make now the time...more