News & Analysis as of

Closely Held Businesses Tax Court

Rivkin Radler LLP

Writing Off A Loan – Simultaneous COD Income and Bad Debt Deduction? Not Necessarily

Rivkin Radler LLP on

If you’ve been around closely held businesses long enough, you know that a transfer of money between a business and its owner, or between two related businesses, is sometimes characterized by the parties as a loan (“related...more

Rivkin Radler LLP

Not Aware of Your Business Partner’s Tax Situation? Maybe You Should Be

Rivkin Radler LLP on

If you’ve worked with the owners of closely held businesses for even just a few years, you have realized they are only half joking when they complain about having the government as a partner. Consider how much federal, state,...more

Rivkin Radler LLP

Trust Fund Recovery Penalty & The Closely Held Business

Rivkin Radler LLP on

Depending upon what you read or, perhaps more accurately, depending upon how much you believe of what you read, you may be aware that many closely held businesses are concerned about their future. Most of these survived...more

Rivkin Radler LLP

Shareholder-Transferee Liability for a Corporation’s Income Tax

Rivkin Radler LLP on

Would you be surprised to learn that most shareholders of closely held corporations, and especially those with minority or merely passive interests, believe they cannot be held responsible for the tax obligations of their...more

Rivkin Radler LLP

The Family-Owned Business, Stock Options, And Personal Goodwill – a Smorgasbord of Tax Issues

Rivkin Radler LLP on

Many of us have encountered variations of the following scenario: a parent owns and operates a business; one or more of their children are employed in the business; as the children mature and become more experienced and...more

Rivkin Radler LLP

Intercompany Loan Treated As Constructive Distribution and Contribution

Rivkin Radler LLP on

Heads I Win, . . . - When closely held corporations that are under common control engage in any intercompany transaction, it is prudent for the corporations and their shareholders to ensure that the transaction is being...more

Rivkin Radler LLP

Transferee Liability for Estate Tax: The Downside of Being a Beneficiary

Rivkin Radler LLP on

Death of a Parent- In the context of a family-owned business, it is often the case that the matriarch or patriarch of the family is also the chief executive of the business. They may have founded the business, or they may...more

Rivkin Radler LLP

Should Closely Held Businesses Be Charitable?

Rivkin Radler LLP on

Faulty Framework? The question posed above is not intended to be rhetorical. Rather, it is one that the owners of a closely held business should consider thoroughly before transferring or committing any business assets to...more

Rivkin Radler LLP

Debt or Equity? The Never-Ending Question For Closely Held Businesses

Rivkin Radler LLP on

What Was Intended? Transactions between commonly controlled, closely held businesses are often conducted in an informal manner. This is unfortunate because, in the absence of documentation, it is sometimes difficult to...more

Rivkin Radler LLP

The Closely Held Business and The Tax Gap

Rivkin Radler LLP on

Have you ever wondered whether you were barking up the wrong tree? That the solution to a problem may be found, not in the approach to which you were already committed and invested, but in an altogether different direction?...more

Rivkin Radler LLP

Business Expenses Paid by Shareholder, But Whose Deduction Is It?

Rivkin Radler LLP on

Constructive Transfers- It is axiomatic that the tax treatment of interactions between a closely held business and its owners will generally be subject to heightened scrutiny by the IRS, and that the labels attached to such...more

Rivkin Radler LLP

Unreasonable Compensation As Constructive Dividend, Redux

Rivkin Radler LLP on

An often-explored theme of this blog is the frequency with which similarly situated owners of similarly situated closely held business, facing a similar set of economic circumstances, and presented with a similar set of...more

Rivkin Radler LLP

Constructive Dividends and The Closely Held C Corporation

Rivkin Radler LLP on

Withdrawing Value- Any tax adviser who has represented closely held businesses and their owners long enough realizes there are certain recurring themes that transcend the otherwise unique characteristics of the industry of...more

Rivkin Radler LLP

Deferring the Tax Hit on a Grant Equity to an Employee – Are You Prepared to Enforce the Forfeiture Provision?

Rivkin Radler LLP on

“Would I ever leave this company? Look, I’m all about loyalty. In fact, I feel like part of what I’m being paid for here is my loyalty. But if there were somewhere else that valued loyalty more highly, I’m going wherever they...more

Rivkin Radler LLP

Tax Changes In The Offing? “Close Scrutiny” Of Business Owners’ Economic Benefits Remains A Constant

Rivkin Radler LLP on

I Read the News Today- Much of today’s news is dominated by the future of the Administration’s broadly defined infrastructure plan. Discussions among “those in the know” inevitably turn into debates over the wisdom of...more

Farrell Fritz, P.C.

Transfer Of Funds between Related Entities – Indebtedness Or Something Else?

Farrell Fritz, P.C. on

A closely held business may come to our firm for any number of reasons. The owners may be selling the business, for example, or they may be thinking about spinning off a division. In some cases, the owners are considering the...more

Katten Muchin Rosenman LLP

2016 Year-End Estate Planning Advisory

In 2016, we continued to experience a period of relative stability in our federal transfer tax system and have been able to plan without expecting imminent significant changes to the system. Under the American Taxpayer Relief...more

17 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