The New Proposed Regulations on DAFs: Taxable Distributions and the Penalty Tax
Employee Benefits and Executive Compensation: Getting Ready for 2024 - Qualified Plans — Special Edition Podcast
End of Year Tax Planning: Tips for Healthcare Professionals and Practices
Change of Control: Golden Parachute Rules in the Sale Process
4 Key Takeaways | Mid-Year Tax Update
TELL ME SOMETHING GOOD! Planning for Post-Retirement Medical Expenses with 401(h) Plans
TELL ME SOMETHING GOOD! Planning for Post-Retirement Medical Expenses With 401(h) Plans
NOWOTNY KNOWS SQUAT! Part IV Using Post-Retirement Medical Plans to Raise AUM and Sell Life Insurance
NOWOTNY ON DEATH AND TAXES EPISODE 35 USING POST-RETIREMENT MEDICAL PLANS TO RAISE AUM
COVID-19 Relief in 2021: What Small Businesses Need to Know
The Biden Tax Plan
NOWOTNY KNOWS SQUAT! Helping Financial Advisors Build a Clientele and Assets Under Management (AUM)!
NOWOTNY KNOWS SQUAT! Helping Financial Advisors Build a Clientele and Asset Under Management (AUM)!
KNOCK YOURSELF OUT - RESUSCITATING TAXPAYERS WITH BUYER'S REMORSE!
The Freeman Law Project – Episode 21 – The New York Times and President Trump's Taxes
ROCK OF AGES video
On-Demand Webinar | PPP Loan Forgiveness: Employment and Tax Issues for Borrowers
THE SPLIT DOLLARMINATOR!
In ongoing litigation between the government and Liberty Global Inc. (“Liberty Global”), Liberty Global has appealed a district court’s decision that ruled in favor of the government to the Tenth Circuit. We have previously...more
The IRS’ determinations in a notice of deficiency are generally presumed correct. Therefore, unless specifically excepted by Tax Court Rule or statute, the burden of proof in civil tax proceedings is ordinarily on the...more
The Tax Court recently ruled that a new partnership (“New Shoals”) that is deemed to form on a technical termination may use a taxable year that starts on the date of the termination of the old partnership (“Old Shoals”),...more
The Court of Appeal’s (“CA”) ruling in April 2024 in the case of BlackRock Holdco 5 LLC v HMRC (“BlackRock”) considered the deductibility of interest on a $4 billion intra-group loan put in place as part of the funding...more
In the late 1990s, former Atlanta Braves players John Smoltz and Ryan Klesko formed Big K Farms (“Big K”), a partnership that, over the years, acquired approximately 1,500 acres of land in Georgia for around $4 million. From...more
The U.S. Tax Court recently upheld a determination by the IRS that premium payments to certain microcaptives could not be deducted for tax purposes because the premium payments were not actually for “insurance.”...more
In the latest victory for taxpayers, the Tax Court determined that the Treasury failed to follow federal law in enacting a conservation easement perpetuity rule known as the “proceeds regulation.” The majority opinion held...more
Over an objection by the IRS, the Tax Court recently ruled in Kapur v. Commissioner that it could limit discovery and permit statistical sampling of voluminous data related to a claimed research credit. The court refused,...more
The Office of Tax Appeals (OTA) handed Microsoft an enormous win in its controversy with the California Franchise Tax Board (FTB) over the inclusion of qualifying dividends in the sales factor denominator for which it also...more
Two recent tax court cases paint an ominous picture for professionals and investors who participated in listed syndicated conservation easement transactions. Coming on the heels of the Fisher conviction and his lengthy...more
Financed transactions can result in states asserting "heads I win, tails you lose" by taking the tax at the time of sale but not accepting pain when the installment sale is busted. When a sale of tangible personal property...more
Hope you had a good Thanksgiving Holiday. Some of us probably feel we ate or drank either too much or not enough, watched too much or not enough football, or spent too much time discussing politics and the state of the...more
Liberty Global Inc. (“LGI”) avoided tax from the sale of a Belgian subsidiary by claiming a dividends received deduction for the entire amount of $2.6 billion in gain. The government challenged this result on economic...more
The recent Tax Court opinion in Hyatt Hotels Corporation v. Commissioner of Internal Revenue informs a federal income taxpayer about its tax responsibility for funds for a guest reward program: when the taxpayer will be...more
On August 9, 2023, the Seventh Circuit Court of Appeals in Hoops, LP and Heisley Member, Inc., Tax Matters Partner vs. Commissioner of Internal Revenue, affirmed the Tax Court’s 2022 decision denying a deduction to a plan...more
Faulty Framework? The question posed above is not intended to be rhetorical. Rather, it is one that the owners of a closely held business should consider thoroughly before transferring or committing any business assets to...more
In an opinion released July 27, 2023, the Third Circuit affirmed a 2021 Tax Court decision upholding a pharmaceutical company’s immediate deduction of patent defense litigation costs in suits brought under the Hatch-Waxman...more
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
Court Determines That ‘Obviously Wrong’ Crime Does Not Require Proof of Blameworthy Intent- United States v. Heinrich (January 23, 2023), No. 21-2723- http://www2.ca3.uscourts.gov/opinarch/212723p.pdf Unanimous decision:...more
Summary: In this 49-page opinion the Tax Court addresses a deficiency arising from the charitable contribution of appreciated shares of stock in a closely held corporation to a charitable organization that administers...more
Check out our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of March 13, 2023 – March 17, 2023...more
Summary: Petitioner Gayla Moore was the sole owner of Nevco, Inc. (Nevco), a subchapter S corporation, during the tax years in issue (2014 and 2015). Nevco claimed the section 411 credit for increasing research activities...more
Summary: Since 1982, James William Avery (Avery) was a practicing lawyer, specializing in personal injury law as a solo practitioner primarily in Denver, Colorado for the period 2008–2013 but also some in Indiana during...more
Summary: In September 2016 Dolomite Holdings 251, LLC (Dolomite), acquired a 723-acre tract of land in Virginia. On November 28, 2017, Dolomite contributed 207 acres of this tract (Property) to Cattail in exchange for a 100%...more
Structuring a family’s investment activities can be complex. Across assets, activities, relationships and the particular circumstances of each family member-investor, a family office will typically provide a spectrum of...more