Sometimes tax motives overwhelm philanthropic motives, which has often been the case with charitable deductions for so-called “conservation easements.” For years now, sponsors have offered up investments in partnerships,...more
In a case of first impression, Frank Aragona Trust v. Commissioner, 142 T.C. No. 9 (Mar. 27, 2014), the Tax Court held that a trust could materially participate in a trade or business based upon the activities of the...more
5/7/2014
/ Internal Revenue Code (IRC) ,
Investment Management ,
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Limited Liability Company (LLC) ,
Materiality ,
Real Estate Investments ,
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Tax Exemptions ,
Trustees ,
Trusts
Most practitioners have now heard of “series” limited liability companies. Series companies (and series partnerships) have been around for quite some time now in Delaware and are becoming more familiar as series organization...more