Current News

Corporate Share Capital, or stock, is one of the most written about things in the Internal Revenue Code and regulations.  Everything seems to be about stock.  Yet many tax advisors miss massive opportunities to save tax on stock transactions every day. Recently we...

Carried interests are a useful tool for partnerships to compensate highly talented employees in a tax efficient way - as capital gain.  This rule allows granting a profits only partnership interest to the employee, and then after service that merits a significant...

In Williams v. Commissioner, 110 AFTR 2d 2012-5639, the Fourth Circuit Court of Appeals has recently ruled that the willfullness penalty under the Foreign Bank Account Reporting (FBAR) regime can apply when the government has scant facts showing willfullness (but bad...

Good news for taxpayers needing to make an Offer-in-Compromise because they can't pay tax bills in full - the IRS is making helpful changes to the way it calculates a taxpayer's reasonable collection potential, including looking at fewer years of future income.  This...

The IRS says incomplete descriptions are being used to mask transactions on the new Form UTP. The UTP is where public companies who have FIN 48 declarations in their Securities filing declare those same "Uncertain Tax Positions" to the IRS.  The IRS says these...

Under IRC Sec. 83(a), gross income includes the value of property received in connection with the performance of services less the amount paid (if any) at the time rights to the property are not subject to a substantial risk of forfeiture or transferable. Taxpayer...

Did you know that retirement plan assets are exempt from creditors in Bankruptcy? This makes retirement plans an asset protection tool. A recent Bankruptcy case (Clark, D.C., Wis) settled the matter once and for all. In this case, the IRA was an asset protection tool...

If you, your spouse or dependents had significant medical or dental costs in 2011, you may be able to deduct those expenses when you file your tax return. Here are eight things the IRS wants you to know about medical and dental expenses and other benefits. 1. You must...