As part of an IRS Examination under the Foreign Investment in Real Property Tax Act (FIRPTA) you absolutely must have a Taxpayer Identification Number (TIN) to mitigate 26 U.S. Code § 1445 - Withholding of tax on dispositions of United States…
Schumann v. IRS: Reg. 1.469-2(f)(6) - The Nuanced Relationship Between Passive Losses & Self Rental Gains. Back to my friends that I previously wrote about who misunderstood passive activity and material participation. They are a married couple filing jointly and own…
Many people have built impressive residential real estate portfolios one property at a time, living in the property while fixing it up thus declaring it their primary residence for income tax purposes and then moving onto a new house to…
That's right Y'all this is another one of those quite game changers for owners of tangible property concerned about keeping the IRS at bay by actually adhering to the specific US Tax Code and subsequent IRS Revenue Procedures. My apologies for…
More and more taxpayers it seems are finding themselves compelled to engage in a structured installment sale of closely held business assets or rental real estate and I couldn't help but notice that there are some common misconceptions about the…
Tax Implication of Publicly Traded Partnerships: Why Purveyors or the US Tax Code Snarl at Investment Brokers. My friend Roger Botterbusch recently put together a most excellent presentation on the tax implications of owning Publicly Traded Partnerships (PTPs), also commonly referred…
I have another new client who is a day trader and wow is he good at it! Even though he has another job he makes so much more money as a trader that this ultimately is his primary vocation. The…
Check out the following 5 lessons I learned this week regarding IRC 351 nonrecognition transactions: 1. The basis assigned to stock received generally is the same as the basis in the property transferred to the corporation. If however you also…
Determining Tax Basis and Holding Period for Non Passive Activities is one of those 'Secrets of the Golden Flower' that seems to be both completely esoteric and yet oh so real at the same time. Let's take a closer look…
Generally when §1231 gains exceed §1231 losses during the year, the net §1231 gain is taxed as a long-term capital gain. However, if there are nonrecaptured §1231 losses from prior years, the net §1231 gain is taxed as ordinary income…
IRS PTIN: P00605639
Enrolled Agent #: 85353
Email: john@johnrdundon.com
