IRS Seeks to Enforce Summons Related to Deferred Sales Trust
We have previously spoken about monetized installment sales (“MISTs”) on Dollars & Sense. According to the IRS, these structures typically seek to defer gains associated with the sale of an...
View ArticleThe Fine Print: IRS Examination of Artwork
Many taxpayers have art collections. However, the art collections of some high-net-worth individuals, family offices, and business taxpayers may draw the unwanted eye of the IRS. With the increased...
View ArticleThe Taxman, Technology Litigation and Cavalier Settlement Structures
Intellectual property (“IP”) is hugely important to businesses. Given that importance, IP owners must occasionally litigate against the unauthorized use of their technology. The costs of such...
View ArticleTravel Alert: How IRS Debt Can Affect Your Passport
By law, the IRS certifies taxpayers with “seriously delinquent” tax debts to the Department of State affecting passport status and renewal when certain conditions or thresholds are met. The IRS will...
View ArticleTony Box Quoted by Tax Notes on ERC Voluntary Disclosure Limits
The IRS’s ERC voluntary disclosure program has drawn concern from tax attorneys due to uncertainty around entering into the program and still being subjected to criminal prosecution. Extensive...
View ArticleTax Court Finds that SECA Limited Partner Exception Requires ‘Functional...
Co-author Caleb O’Donnell* A recent U.S. Tax Court decision provides clarity to what the Internal Revenue Service (“IRS”) considers a limited partner for purposes of the ‘limited partner exception’ to...
View ArticleDollars & Sense Editor Joshua Smeltzer to Speak on Attorney-Client Privilege...
Gray Reed Partner and Dollars & Sense Editor Joshua Smeltzer will be speaking at Convergence 2024, TXCPA Dallas’ premier continuing professional education event. Scheduled for May 10, 2024, at the...
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Tax Court Decision on Family Business Affecting Income Tax, Estate Tax
In a recent Tax Court decision, the court reviewed the activities of the Huffman family as it pertained to corporate dealings involving the family aviation business (Infinity Aerospace Inc. which the...
View ArticleFederal Income Taxation of Intellectual Property Development and Cost Recovery
Intellectual property (“IP”) development can cost millions of dollars so cost recovery timing can be financially material. General tax principles typically require that expenses associated with...
View ArticleGray Reed Partner Austin Carlson to Speak on Doing Business in the United States
Gray Reed Partner Austin Carlson will be speaking on a panel webinar hosted by the Enterprise Europe Network, the world’s largest business service provider. Scheduled for April 18, 2024, at 4 pm CST...
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