I was talking with a taxpayer the other day who registered as an LLC with Colorado Secretary of State. She developed an intriguing business model that is doing remarkably well according to the financial statement. As part of a tax…
I was talking with a taxpayer the other day who registered as an LLC with Colorado Secretary of State. She developed an intriguing business model that is doing remarkably well according to the financial statement. As part of a tax…
Unless you elect different treatment, for shareholder income tax purposes S corporation distributions are applied in the following order: 1. To reduce the Accumulated Adjustment Account (AAA) determined without regard to any net negative adjustment for the tax year but…
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…
Most anniversaries are celebrated with joy and jubilation. But on February 3rd, 2013, I doubt that anyone will be celebrating this anniversary or should I say centennial - after all, it is the 100th anniversary of the 16th Amendment to…
The distinction of how this is possible distills down to understanding the nuanced difference between a 'Continuous' and a 'One Time' IRS tax levy. Under Code Sec. 6331(h) once a tax levy is approved, the effect of the levy on specified…
Certain entities, such as partnerships, are required annually to file K-1s with the IRS and provide a copy to their partners. The IRS estimates that partnerships filed almost 26 million K-1s during 2011. Revenue Procedure 2012-17 provides new rules describing when partnerships may…
Daniel N. Shaviro (NYU) has published The Optimal Relationship between Taxable Income and Financial Accounting Income: Analysis and a Proposal, 97 Geo. L.J. 423 (2009). Here is the abstract: The persistence of the book-tax gap, or excess of companies’ reported…