This article focuses on “related party” transactions under Internal Revenue Code Section 267(a)(1) and Internal Revenue Code Section 1239(a). While there is some overlap, it should be noted that the specific scope of “related parties” for purposes
A less well-known rule that can affect the tax deduction of losses from the sale of stock is the wash sale rule, enacted under Internal Revenue Code Section 1091. This article discusses the application of the wash sale rule.
It has been stated that the limited liability company has become more popular than the corporation as the basic form of entity to do business in the United States. A critical document with any limited liability company is the operating agreement. When
President Trump announced a new immigration proposal – what he referred to as a “gold card”. The “gold card” green card program would potentially replace the existing EB-5 immigration program. Although it has been reported that the Trump
Effective estate tax planning often involves two competing objectives. On one hand, there is an objective to remove assets from a person’s taxable estate, so that estate tax liability can be reduced on such person’s death. On the other hand, there
With the Supreme Court’s decision to stay the “Texas Top Cop Shop December 3” injunction, the Supreme Court’s decision only related to the nationwide injunction issued in the Texas Top Cop Shop case; it did not at all relate to the nationwide
In school, we learn that there are three branches of the United States government – legislative, executive, and judicial. In fact, many commentators believe that there is a fourth branch – the administrative branch. Carved out of the executive
President-elect Trump has proposed various new specific exemptions from income tax liability. First, he would exempt tips from income tax liability. Second, he would exempt overtime pay from income tax liability. Third, he would exempt Social Security
Chapter 22 of the Su Wen ends with a summary of the five (5) flavors: sour, sweet, bitter, salty and pungent/acrid. Five grains are used as main food, five fruits as supplementary food, five animal meat as beneficial food, and five vegetables as adjuvant
Charitable activities are favored under the Internal Revenue Code. The income of a charitable entity can be subject to favorable income taxation, and transfers to a charitable entity can realize income tax and estate tax deductions. One type of charitable
There are two types of reporting companies – “domestic reporting companies” and “foreign reporting companies.” It is important to remember that reporting companies that were formed or registered to do business in the United States on
“Buy sell” agreements often are funded by life insurance policies. Life insurance proceeds can affect the “estate tax” valuation of a deceased business owner’s ownership interest. And can have material implications for the terms of “buy-sell”