Partnership catches unexpected break

Sometimes the IRS gives you a second chance. That was the case in a private letter ruling the IRS issued to an unnamed partnership. But remember that private letter rulings cannot be cited as authority for anyone other than the taxpayer to whom it was issued. When the...

Lending to employer? Check your motive

Shareholders or employees of a corporation often lend it funds – expecting to be repaid. If the loan does not get repaid, a bad debt deduction can be claimed. However, the tax treatment is different for “business” bad debts and...

Donating noncash asset? Have a qualified appraisal

As demonstrated in several recent court cases, the IRS is taking an aggressive position in issues involving valuations of noncash charitable contributions. Rather than challenging the value placed on the asset, the IRS is challenging whether the valuation is supported...

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?...