When a C corporation sells its assets, it recognizes gain equal to the excess of the amount realized on the sale (generally, the purchase price plus any liabilities assumed or taken subject to) over the adjusted basis of the assets being sold. This gain is subject to a corporate-level Federal income tax at a maximum
Rescinding a Transaction
As kids playing ball, we learned about the “do-over” rule; following an unintended result at the plate, the player in question was allowed to try again, without penalty. As we got older and our games changed, we learned about “taking a mulligan”, again without penalty. It may not come as a surprise that a variation
S Corp Sales, Built-In Gain, and 2013
Last year saw many taxpayers selling appreciated assets. The primary reason for this activity was the imminent increase, in 2013, of the long term capital gain rate, and the imposition (in some cases) of a 3.8% tax on net investment income, both of which would impact sales of assets owned directly by individuals or
Foreign Accounts: Now Is The Time To Disclose
The Internal Revenue Service is serious about cracking down on U.S. taxpayers who have failed to disclose the existence of foreign accounts in which they have a financial interest, or over which they have signature authority. Typically, these same taxpayers have failed to report certain transactions on their tax returns, the proceeds of which reside
Obama’s 2014 Budget Estate and Gift Tax Proposals: How Might They Impact Your Estate Plan?
As we reached the end of 2012 and the expiration (or so we thought) of the $5 million gift/estate tax exemption, many taxpayers scrambled to make gifts to, or for the benefit of, their family members. With these gifts, they sought to remove assets, and their appreciation, from the reach of the estate tax. 
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