Sometimes you go for weeks without having to consider a particular tax issue in any depth. Then, unexpectedly, that issue comes to the forefront of several projects. That was my experience this past week when it seemed as though almost every other person who came to my office had a question concerning
Ask a business owner to identify the parties to an agreement for the purchase and sale of the stock of a target corporation, perhaps even their own. After giving you a quizzical look,[i] they will likely reply that, on the one hand, you have the target’s shareholders, who will be selling
On September 9, 1776, Congress officially adopted “United States” of America as the name of our then-newly-born nation. The former British colonies had previously referred to themselves as the “United Colonies.” In March of 1781, the Articles of Confederation went into effect, after having been ratified by all thirteen States.
Last week, New York’s Governor Cuomo released his proposed budget for the State’s 2021 fiscal year. After criticizing the Federal limitation on itemized deductions for state and local taxes,[i] the Governor commented on the “out-migration” from the State of many high-earning New Yorkers, thus implying a causal connection between
The experienced or well-informed investor recognizes that there is an element of risk in every business venture. They understand that the cash or other property they have contributed to the venture may be lost for any number of reasons – an economic downturn, a very competitive industry, the incompetence of officers, an adverse
A couple of months back, a local business reporter asked whether I could identify one kind of corporate transaction that was occupying more of my time than any other. When I asked whether they were referring to any specific industry, form of M&A transaction,[i] or type of buyer,[ii] they replied that they were
On December 3, 2019, Taxpayer timely[i] filed a notice of appeal from a decision of the U.S. Tax Court that had been entered approximately two months earlier.[ii]
Because Taxpayer is a corporation, the Tax Court’s decision will be reviewed by the Court of Appeals for the Ninth Circuit, which
This is the final weekend of the final month of the final year of the decade. As the clock ticks away the hours, many folks are busy returning gifts, planning New Year celebrations, scheduling college bowl game parties, debating who was the best quarterback of the decade,[i] ignoring
At the beginning of every week, after posting that week’s article, I start to think about a topic for the next post. There are times when I struggle to find something that may be appealing in and of itself, or that may, perhaps, provide a vehicle
A couple of years ago, this blog carried an article that briefly considered whether the gain realized by a taxpayer on the sale of a contract should be treated as ordinary income or capital gain for tax purposes.[i]
As it turned out, that piece has been one of the most popular articles that we