Legal Updates & Commentary for Tax & Estate Planning
As we approach the presidential convention season,[i] and the election campaign that will follow, the thoughts of many business owners have turned to the federal estate tax, and for good reason.[ii]
After the Great Recession of 2007-2009,[iii] the economy enjoyed a period of sustained growth of approximately 11…
Monday morning quarterbacking – the connotations are anything but positive.
Life is full of instances in which someone, in possession of all the factors that informed – or that should have informed, had they known about them – another’s earlier decision, and with full knowledge of the outcome of such decision,…
Over the last several weeks, we have explored various aspects of the choice of entity dilemma that confronts the owners of many closely held businesses, and we have considered how the Tax Cuts and Jobs Act[i] may influence their decision.
In the process, you may have realized that one form of…
Dr. Wallace Wrightwood: “You’ve seen hundreds, thousands of pigeons, right?”
George Henderson: “Of course.”
Dr. Wallace Wrightwood: “Have you ever seen a baby pigeon? Well neither have I. I got a hunch they exist.”[i]
When was the last time you pored over a judge’s analysis of the bona fides of a family limited partnership (“FLP”),…
I recently encountered a situation in which the so-called “basis consistency” rule was implicated. This rule requires consistency between the estate tax value of a decedent’s property – its fair market value (“FMV”) as reported on the decedent’s estate tax return – that passes to a beneficiary, and the basis claimed by…
Missed Part I? Check it out here!
“Related Party” Transactions
Transfer Pricing
Valuations figure prominently in determining the proper tax treatment of transactions – such as sales, loans, leases, and performance of services – between related taxpayers, including, for example, commonly-controlled business entities.
The IRS is authorized to allocate items of income or deduction, or…
One word: “taxes.” There are so many transactions in which the tax consequences visited upon a closely-held business and its owners, and, therefore the true economic cost of the transaction, will depend upon the valuation of the business, its property, or its equity.
The following discussion highlights some of the more commonly-encountered situations in which…
