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Different Sources of Income Matter FDAP v. ECI

The Perturbing New Treatment of Patents Under the Tax Cut & Jobs Act (TCJA)

Different Sources of Income Matter FDAP v. ECI One of the issues difficult for some of my international clients to grasp about the United States is its taxation of citizens and resident aliens alike on their worldwide income without any

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Posted in Alien, Alimony, Distributions, Expatriation, Foreign Income, Foreign Investment, International Tax, Paying Taxes

Use IRS Form 8082 to Report An Incorrectly Issued K1

This post address how to use IRS Form 8082 to report an incorrectly issued K1. The lesson learned is that you always start by requesting in writing that a corrected K1 be issued. I've been working a very complicated file

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Posted in 1231 Exchange, Asset Classification, Audit Reconsideration, Business Income, Capital Loss, Distributions, IRS Appeal, IRS Audit, IRS Collections, IRS Enforcement, K1, Partnership, Passive Activity, Sub-chapter S, Tax Guidance & Preparation, Tax Problems & Requests, Uncertain Tax Position

Allowable Nontaxable IRA Rollovers Contributions Interpreted To Mean One Per Taxpayer Per Tax Year in US Tax Court Case – Bobrow v. Commissioner

In Bobrow v. Comm'r, T.C. Memo. 2014-21, the Tax Court relied on IRC 408(d)(3)(B) regarding the limits and frequency of nontaxable rollover contributions elected by the taxpayer noting that the one-year limitation addressed in this section of the US Tax Code applies

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Posted in Distributions, Investment Income, IRA, IRS Enforcement, IRS Examination, Retirement, Tax Court, Tax Guidance & Preparation, Tax Problems & Requests

Tax Treatment of Liabilities Assumed by a Corporation IRC 357 – What is Boot?

According to IRC 357(a) if property transferred to a corporation in an IRC 351 nonrecognition transaction is subject to a liability, the assumption of that liability by the corporation generally is not treated as taxable "boot" for purposes of determining the amount

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Posted in Abusive Tax Shelter, Basis, Boot, Capital Gain, Capital Loss, Cash Transaction, Deductible Expense, Distributions, Tax Guidance & Preparation

Tax Treatment of a Reverse Mortgage

A reverse mortgage is generally a loan where a lender pays a lump sum, a monthly advance, a line of credit, or a combination of all three to you while you continue to live in your home and retain title to it.

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Posted in Death, Debt, Deductible Expense, Dependent, Distributions, Family, Mortgage

Characterizing Partner Distributions

Generally if payments are in exchange for partnership property, the amount received in excess of the partner’s outside basis in his/her partnership interest is taxed as capital gain. However if the payments represent a distributive share of partnership income or are deemed to be guaranteed payments, the payments

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Posted in Cost Basis, Distributions, Investment Income, Retirement, Small Business, Tax Guidance & Preparation, Taxable Income

How to Properly Close Down Your Business

Closing down your business is hard and heart breaking and if you are at the point that you are actually reading this post then people have probably been nagging you for money and you are at the end of your

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Posted in Appeals & Audit Resolution, Asset Classification, Back Taxes Owed, Debt, Disallowed Expenses, Distributions, Entity Classification, IRS Collections, IRS Enforcement, IRS Levy, IRS Lien, Net Operating Loss, NOL, Paying Taxes, Self Employ, Small Business, Sole Proprietor, Stock Options, Tax Guidance & Preparation, Tax Problems & Requests, Tax Relief

Characterizing Liquidating Distributions – Wallis, et ux. v. Commissioner TC Memo 2009-243

Liquidating payments made by a partnership to a retiring partner are governed by §736.  In general, if the payments are in exchange for partnership property, the amount received in excess of the exiting partner’s outside basis in his partnership interest is taxed as capital gain.  On the

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Posted in Distributions
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