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Considerations of S-Corp Acquisitions
Federal Taxation
When buying or selling a business, the existence of a target company that is taxed as a subchapter S corporation (an “S…
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Proposed Bipartisan Legislation on Opportunity Zones and Qualified Opportunity Funds Would Extend the Investment and Gain Deferral Period By Two Years and Permit Investment in a Fund of Funds
Federal Taxation
On September 27, 2023, H.R. 5761, the “Opportunity Zones Transparency, Extension and Improvement Act,” was introduced as…
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Recent Court Decision Highlights the Split in Authority Concerning the Estate Tax Treatment of Life Insurance under a Buy-Sell Agreement
Federal Taxation
In Connelly v. United States, No. 21-3683 (8th Cir. 2023), the United States Court of Appeals for the Eighth Circuit, on the…
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Recent Tax Court Case Contains Detailed Discussion of Gift Tax Adequate Disclosure Requirements
Federal Taxation
Schlapfer v. Commissioner, T.C. Memo. 2023-65 (U.S. Tax Court May 22, 2023), is the first reported caseto contain a detailed…
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Impact of SECURE 2.0 on Planning for Trusts
Federal Taxation
The last two articles the author wrote, Dealing with Proposed Regs under the SECURE Act and Strategy Under the SECURE Act,…
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Recent IRS Challenges to Grantor Retained Annuity Trusts (GRATs)
Federal Taxation
There are two separate significant IRS challenges to grantor retained annuity trusts (GRATs) in the context of ongoing merger…
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Final Subpart F Regulations and Domestic Partnership Tax Reporting
Federal Taxation
Introduction On January 25, 2022, the Department of the Treasury and the Internal Revenue Service (collectively, “the…
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Nothing to Fear but Fear Itself: Planning in the Current Environment
Federal Taxation
As the calendar turns to 2023, taxpayers and their advisors face an uncertain future. Given a divided government for at least…
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Code Section 754: Allocating Gain Where it Belongs
Federal Taxation
The genesis of Code Section 754 stretches back to the first third of the 20th century, as the IRS tried to combat tax…
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