The Treasury Department’s issuance of proposed regulations under Code Section 2704 were met with significant criticism and confusion. The §2704 proposed regulations were intended to provide the IRS with an additional sword to reduce and in some cases eliminate valuation discounts on family-controlled business entities. After thousands of comments were…
Related: Corporate
Clear FilterTax Residency and the 2017 World Rowing Championships
The Sarasota-Manatee area recently hosted the 2017 World Rowing Championships, bringing nearly a thousand athletes from seventy countries to the world-class rowing facilities at Nathan Benderson Park. The tax consequences of such a visit were probably far from the thoughts of the rowers, coaches, support teams, and fans arriving from…
Applicable Federal Rates for October 2017
The Internal Revenue Code prescribes minimum imputed interest rates and time-value-of-money factors applicable to certain loan transactions and estate planning techniques. These rates are tied formulaically to market interest rates. The Internal Revenue Service updates these rates monthly. These are commonly applicable rates in effect for October 2017: Short Term…
Why the President’s Latest Tax Reform Proposal Isn’t Even Nine Times Very Little
In April, the last time tax reform bubbled into the news cycle, we discouraged readers from paying much attention. President Trump’s “proposal” was this single page of bullet points that told us too little to evaluate its merit. Tax reform returned to headlines this week, with the President offering this…
IRS Declines to Follow Tax Court Decision Liberalizing Reverse 1031 Exchanges
Last year on the blog, we reported a Tax Court decision approving “reverse” 1031 Exchanges in which a taxpayer acquires replacement property more than 180 days before disposing of relinquished property. The IRS recently announced it will not follow the Tax Court decision and may seek future challenges in other…