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Tax Deductions Business Losses Internal Revenue Service

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...

Foster Garvey PC on

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

Partnership Losses on Related Party Sales – The IRS Provides Some Clarification

Rivkin Radler LLP on

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

Rivkin Radler LLP on

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

Foster Garvey PC

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

Foster Garvey PC on

...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

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

Rivkin Radler LLP on

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.

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

Troutman Pepper on

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

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