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HTMLIRS Streamlines Offshore Voluntary Disclosure Program
Thomas Lawson, Alan J. Tarr; Loeb & Loeb LLP;
Legal Alert/Article
October 2, 2014, previously published on September 2014
On June 18, 2014, the IRS announced new Streamlined Filing Compliance Procedures (Streamlined Programs) and changes to the existing Offshore Voluntary Disclosure Program (OVDP). These programs are intended to help taxpayers correct any failures to report foreign financial assets and income (and to...

 

HTMLIRS Issues Additional Guidance as to When Construction Begins for Production Tax Credit
Alan J. Tarr; Loeb & Loeb LLP;
Legal Alert/Article
October 2, 2014, previously published on September 2014
As described in prior newsletters, a taxpayer is entitled to a production tax credit (PTC) with respect to sales of electricity from certain qualified facilities where construction of the facility began before January 1, 2014. The IRS had previously provided two methods to determine when...

 

HTMLTax Court Attributes Significant Value to Personal Goodwill in Estate Tax Valuation Case
Thomas Lawson, Alan J. Tarr; Loeb & Loeb LLP;
Legal Alert/Article
October 2, 2014, previously published on September 2014
Two months after the Tax Court decided the Bross Trucking case, it addressed the significance of personal goodwill in valuing the stock of a closely held corporation, STN.Com Inc. in Estate of Franklin Z. Adell, TC Memo 2014-155. The decedent, Franklin Adell, owned all of the shares of STN stock....

 

HTMLTaxpayer Avoids Penalties by Relying on Professional Advice
Thomas Lawson, Alan J. Tarr; Loeb & Loeb LLP;
Legal Alert/Article
October 2, 2014, previously published on September 2014
In the recent Tax Court case of Vision Monitor Software LLC v. Commissioner (September 3, 2014), the Tax Court disallowed a taxpayer’s deduction for losses incurred by a partnership in which he was a partner because he did not have sufficient income tax basis in his partnership interest to...

 

HTMLMontgomery County Council Introduces Expedited Bill for Parking Lot District Exemptions
Todd D. Brown, Yum Yu Cheng, C. Robert Dalrymple, Heather Dlhopolsky, Stephen P. Elmendorf; Linowes and Blocher LLP;
Legal Alert/Article
October 2, 2014, previously published on September 24, 2014
On September 23, 2014, the Montgomery County Council introduced Expedited Bill 43-14 regarding tax exemptions in the County's Parking Lot Districts (PLDs), with a public hearing tentatively scheduled for October 14, 2014.

 

HTMLCourt Holds That Land Sold Was Inventory That Gave Rise to Ordinary Income
Thomas Lawson, Alan J. Tarr; Loeb & Loeb LLP;
Legal Alert/Article
October 2, 2014, previously published on September 2014
We normally think that selling a parcel of land one has held for a long period of time will result in capital gain income subject to federal income tax at a lower rate than ordinary income. A recent court decision reminds us that this is not always the case. Mr. Allen purchased a parcel of real...

 

HTMLWhat You Need to Know About Corporate Inversions
Thomas Lawson, Alan J. Tarr; Loeb & Loeb LLP;
Legal Alert/Article
October 2, 2014, previously published on September 2014
It seems like every day brings news of another possible corporate inversion transaction. The news reports usually describe these transactions as another United States corporation moving or relocating outside of the country. While the management of the U.S. company tries to downplay the tax impact,...

 

HTMLAnother Taxpayer Mistake Causes Loss of Charitable Contribution Deduction
Thomas Lawson, Alan J. Tarr; Loeb & Loeb LLP;
Legal Alert/Article
October 2, 2014, previously published on September 2014
It has become unusual for a month to go by without the tax news reporting another case where a taxpayer has lost a charitable contribution deduction due the failure of the taxpayer to follow all of the rules relating to the particular deduction. We have written about this before but it continues to...

 

HTMLTax Court Addresses Income, Estate and Gift Tax Issues Related to Personal Goodwill
Thomas Lawson, Alan J. Tarr; Loeb & Loeb LLP;
Legal Alert/Article
October 2, 2014, previously published on September 2014
In the recent case of Bross Trucking, Inc., TC Memo 2014-107, the Tax Court again considered whether the shareholder of a corporation was possessed of personal goodwill relative to the business of the corporation. The case is important because the existence of personal goodwill may enable a...

 

HTMLNew York Tax Appeals Tribunal Reverses “Distorted” Knowledge Learning Decision and Provides Guidance for Proving Substantial Intercorporate Transactions
Michele Borens, Jonathan A. Feldman, Jeffrey A. Friedman, Todd A. Lard, Carley A. Roberts; Sutherland Asbill & Brennan LLP;
Legal Alert/Article
October 1, 2014, previously published on Septmeber 25, 2014
On September 18, 2014, the New York State Tax Appeals Tribunal (Tribunal) decided its first combination case addressing the 2007 changes to New York’s combined reporting regime: Matter of Knowledge Learning Corporation and Kindercare Learning Centers, Inc., DTA Nos. 823962 & 823963 (N.Y....

 


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