Federal Taxation

  • 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. 
     
  • Don’t Overlook Your Clients’ IRA Beneficiary Designations

    By:
    Kevin Matz, CPA, Esq., LLM
    |
    Apr 1, 2016
    The beneficiary designation forms for qualified retirement plans and individual retirement accounts (collectively, “IRAs”) are often overlooked in a client’s estate plan. But in many instances, the beneficiary designation forms will control more assets than the will itself. 
  • Social Security Strategies

    By:
    Daniel Mazzola, CPA, CFA
    |
    Feb 1, 2016
    The Social Security Act, was signed into law in 1935, was designed to provide adequate financial assistance to the elderly, the poor, the unemployed, the widowed, and fatherless children.  
  • The Crowdfunding Craze: A Primer for Tax Professionals

    By:
    Sean Mathey, Esq.
    |
    Dec 1, 2015
    The popularity of Internet crowdfunding has exploded in recent years.  As individuals and businesses turn increasingly to this alternative form of financing, the regulatory response has been outpaced, leaving tax and legal advisors on uneven ground regarding client counsel.  
 

 
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