staying out of trouble

In the recent case Thousand Oaks Residential Care Home I, Inc. v. Commissioner, the Tax Court considered whether a corporation’s compensation packages for its owner-employees were unreasonable and thus disallowable as deductions.  The facts can be summarized as follows: in 1973, Petitioners “Mr. and Mrs. F.” purchased a struggling corporation called Thousand Oaks Residential

Historically, the gift and estate tax laws have limited the ability of wealthy individuals to transfer their interests in family businesses to their children without suffering potentially severe tax consequences.  However,  many wealthy taxpayers are interested in shifting the appreciation in their business out of their estate and into the hands of their children.

Transfers

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