Federal Taxation

  • Fundamental Tax Reform Is Mostly Dead—but Not Quite

    By:
    Curtis S. Dubay
    |
    Oct 1, 2016

    In the classic children’s movie The Princess Bride, Billy Crystal plays a miracle-performing medicine man. When the hero of the story is brought to him, Crystal’s character says that he is “mostly dead.” That is an apt description of fundamental tax reform’s current state. 

  • Proposed Regulations Under IRC Section 2704

    By:
    Kevin Matz, Esq., CPA, LLM (Taxation)
    |
    Oct 1, 2016

    On Aug. 2, 2016, the U.S. Department of the Treasury and the IRS issued proposed regulations under IRC Section 2704 (the “Proposed Regulations”) that, if enacted in its present form, might significantly curtail the ability of taxpayers to claim valuation discounts for both lack of control and lack of marketability in family-controlled entities. 

  • A Brief Update on Filing Requirements for U.S. Citizens Living Abroad and Resident Aliens in the United States

    By:
    R. John Smith, Esq.
    |
    Oct 1, 2016

    Who has to file Form 1040NR? Form 1040NR may need to be filed if a specified individual is a nonresident alien engaged in a trade or business in the United States, represented a deceased person who would have had to file Form 1040NR, or represented an estate or trust that had to file Form 1040NR. See the form’s instructions for more information.

  • Is It Debt or Equity? A Survey of the Proposed Section 385 Regulations

    By:
    James J. Wienclaw, CPA
    |
    Jul 1, 2016
    The fundamental question investors address when capitalizing a business is how it should be funded—with debt, equity, or a combination of both. Considerations can vary widely depending on the level of risk an investor is willing to take or the desired tax treatment.
  • New Seller Due Diligence Responsibilities After the Midco Cases?

    By:
    Ellen S. Brody, CPA, JD, Esq. and Vivek A. Chandrasekhar, JD, Esq.
    |
    Jul 1, 2016
    In the post-General Utilities world, shareholders have looked to dispose of their interest in C Corporations with appreciated assets in a way that would avoid the double taxation arising on a sale of assets followed by a liquidating distribution to the noncorporate shareholder. 
  • Coming to America – Love, Marriage and Immigration

    By:
    Carole M. Bass and Rebecca A. Provder
    |
    Jun 1, 2016

    In the 1988 hit comedy, Coming to America, Prince Akeem, heir to the throne of Zamunda, flees his home country to escape an arranged marriage. He comes to the United States to find his queen, a woman who will love him in spite of his vast wealth and title. Sure enough, he finds Lisa McDowell, heir to the McDowell’s Restaurant fortune.

  • Foreign Trust Reporting: Substance Over Forms? I Think Not

    By:
    Alicea Castellanos, CPA, TEP, NP and Jack R. Brister, TEP
    |
    Jun 1, 2016
    In a world dominated by data, the IRS’s role in data collection continues to expand. No longer is the agency’s sole focus domestic income tax reporting, collection, and enforcement; rather, today’s IRS is responsible for activity that occurs beyond U.S. borders and disseminating an array of information. 
     
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