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Going in Circles: The IRS Limits Puerto Rico Source Rules in Responding to Aggressive Tax Positions

The tax advantages for US individuals who become bona fide residents of US possessions can be substantial. These tax advantages have lured more than a few taxpayers to take unreasonably aggressive positions that they are...more

Surk v. Commissioner: Excess Losses Claimed in Closed Years Reduce Current Tax Basis

Children learn certain social norms through game playing. In hide and seek, when the seekers exclaim, “alley alley oxen free!” the children in hiding are free to return to home base. It would violate a child’s sense of...more

ESOP Update: Installment Sales Rules Save ESOP Footfall in Berman v. Comm’r

Berman v. Comm’r,  released on July 16, 2024, is a great example of making lemonade when life hands you a lemon. Although the taxpayers lost the federal income tax deferral of a stock sale to an employee stock ownership plan...more

Through the Looking Glass: US Internal Revenue Service Finalizes Cryptocurrency Tax Reporting Regulations

In August 2023, the US Internal Revenue Service (“IRS”) proposed regulations to fulfill the Congressional mandate to require US tax reporting of digital asset transactions by brokers and other intermediaries. After evaluating...more

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