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Sale of a Business and Qualified Opportunity Funds: Deferral, Exclusion, and . . . Risk?

By Farrell Fritz P.C. on February 5, 2019
Posted in Federal Tax Issues

A lot has been written about the tax benefits of investing in a Qualified Opportunity Fund. Some have suggested that the gain from the sale of a closely held business may be invested in such a fund in order to defer the recognition of this gain and to shelter some of the appreciation thereon.

In…

Taxpayers Bear the Tax Consequences of Business Decisions

By Farrell Fritz P.C. on August 21, 2017
Posted in Federal Tax Issues

Form v. Substance

It is a basic precept of the tax law that the substance of a transaction, rather than its form, should determine its tax consequences when the form of the transaction does not coincide with its economic reality. This substance-over-form argument is a powerful tool in the hands of a taxing authority.

According…

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