Frequently, the tax ramifications of litigating or settling a legal case are not considered by the litigants and their attorneys until after the fact. As a result, litigants and attorneys often miss a valuable opportunity to improve their tax position at the time of reaching a settlement agreement with respect to a given legal dispute…. Read more »
Posts Categorized: Uncategorized
Estate Planning Techniques using FLPs Become a Time Sensitive Matter Due to IRS’s Recent Issuance of Proposed Regulations that Attempt to Restrict Valuation Discounts
Proposed regulations released by the IRS on August 2, 2016 would permanently and profoundly change estate planning for families that own a controlling interest in a privately held corporation, partnership, or limited liability company. For these families, estate planning techniques often take advantage of valuation discounts often using so-called “family limited partnerships” in order to… Read more »
Significant Tax Planning Opportunities Available for Like-Kind Exchanges of Oil and Gas Properties
The capital-intensive nature of companies engaged in oil and gas operations and the liberal tax rules that determine the like-kind nature of oil and gas properties combine to make IRC Section 1031 like-kind exchanges incredibly attractive to oil and gas companies. This article discusses why the potential tax benefits available to companies in the oil… Read more »
IRS Issues Partnership Audit Temporary Regulations
On August 4, 2016, the Treasury Department issued its first temporary regulations under the new partnership audit and collection regime found in the Bipartisan Budget Act of 2015 (“BBA”). For partnership tax procedure practitioners, the regulations are interesting reading. These new regulations provide insights into the internal deliberations and policy goals at Treasury and IRS… Read more »