Latest Posts › Tax Planning

Share:

Significant Planning Opportunities Available For Carryback Of NOLS Under The CARES Act

Whether you are in the process of an equity transaction in 2020 or completed one in 2018 or 2019, you may have significant federal income tax planning opportunities. ...more

Tax Court Provides Guidance On Section 165 Deduction For Worthless Equity Interests - Tax Update Volume 2020, Issue 2

In order to take a worthlessness deduction for an equity investment in an entity, including an equity interest in a corporation or a partnership, the taxpayer must show that the instrument is worthless (no value at all), and...more

Recent IRS Technical Advice Memorandum Denies Recovery Of Capitalized Costs Incurred By Target Company Upon Sale Of The Target...

In April 2019, the IRS’s Large Business and International Division (LB&I) issued an LB&I Transaction Unit (LTU) that described potential positions a taxpayer may take to recover previously capitalized transaction costs....more

When Can Capitalized Transaction Costs Be Recovered? Recent LB&I Transaction Unit Provides Insight

Taxpayers typically incur significant transaction costs when undergoing a transaction involving a restructuring, acquisition, disposition, sale of assets, or sale of stock. The default rule under section 263 is that all...more

Transaction Cost Allocation Considerations for Partnerships - What's Different and What's the Same - Tax Update Volume 2019, Issue...

The treatment of transaction costs in the context of a transaction involving a partnership that is either the acquiring entity or the target entity raises unique issues....more

IRS Disallowed Deduction of Success-Based Fees Because of Lack of Documentation - Tax Update Volume 2018, Issue 4

The tax treatment of costs incurred in a transaction can represent a significant deduction for the taxpayers involved. Even in the case of a corporation that is now taxed at the corporate rate of 21 percent, the deduction for...more

Focus on New Tax Law: Section 199A Pass-Through Deduction and Restrictions on Interest Deductions Tax Update, Volume 2018, Issue 2

The Tax Cuts and Jobs Act (2017 Tax Act) significantly modified the treatment of certain deductions for many business taxpayers, including partners and partnerships....more

Effective NOL Planning in Light of Tax Reform

Can your company unlock the value of net operating loss carryforwards to reduce future taxable income? Originally published in Tax Executive, the professional journal of Tax Executives Institute - January/February 2018....more

8 Results
 / 
View per page
Page: of 1

"My best business intelligence, in one easy email…"

Your first step to building a free, personalized, morning email brief covering pertinent authors and topics on JD Supra:
*By using the service, you signify your acceptance of JD Supra's Privacy Policy.
- hide
- hide