The U.S. Tax Court recently issued an opinion in Parkway Gravel Inc. v. Commissioner, Docket No. 10819-21, respecting the structure of a gravel company's sale of a land parcel known as the Freeway Pit. In finding for the...more
When a taxpayer is considering purchasing a foreign corporation, tax planning must be part of the process in order to mitigate unwanted tax consequences. For example, an election under section 338(g) of the Code has been a...more
Like-kind exchanges are well-known events in the field of investment real estate. The tax law has spent about the last 30 years refining the deferred like-kind exchange, in which the taxpayer is given time to locate the...more