Tax Court didn’t inhale

An obscure provision of the income tax law denies all business deductions to anyone whose business involves trafficking in a controlled substance.  Few people agree that it would be good public policy to allow drug dealers a tax deduction for the costs associated...

CROSSING THE BORDER – TO SAVE TAXES?

Recent headlines have highlighted the names of wealthy individuals who have given up their U.S. citizenship, ostensibly to save taxes. Remember Eduardo Saverin, the Facebook founder who renounced his U.S. citizenship on the eve of Facebook’s now legendary IPO?...

HEALTHCARE ACT CONSTITUTIONAL: TAXES AHEAD

Unless you’ve found a way to live without the news media, you’ve already heard that the U.S. Supreme Court upheld most of the Patient Protection and Affordable Care Act of 2010, as amended by the Health Care and Education Reconciliation Act of 2010 –...

DEDUCTION DENIED: IT’S A QUESTION OF SIMILARITY

The IRS Chief Counsel has denied the domestic production activities deduction to a company that sells online software. The domestic production activities deduction (DPAD) is available for domestic production gross receipts from the lease, license, sale or disposition...