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Investment › Internal Revenue Code (IRC) › Tax Court

Rivkin Radler LLP

The Limited Partner Exclusion From Self-Employment Tax – But Who Is A Limited Partner?

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An Agency Under Siege - The mission statement of the IRS reminds taxpayers that it is their responsibility to understand and meet their tax obligations, while it is the role of the IRS to “enforce the [tax] law with...more

Cadwalader, Wickersham & Taft LLP

YA Global Brings its Fight to the Appellate Level

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On April 28, YA Global Investments, LP (“YA Global”) filed an appeal in the 3rd Circuit, contesting the Tax Court’s decision in YA Global Investments, LP v. Commissioner. In YA Global Investments, the court found that YA...more

Rivkin Radler LLP

“Hey Mom, Can I Have A Few Bucks?” Is It A Loan? A Gift? A Little of Each?

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A parent will sometimes transfer money to a child to enable the child to make an investment that the child could not otherwise make on their own. For example, the child may have identified an attractive business opportunity...more

Rivkin Radler LLP

Partnership Transactions Lacking Economic Substance or Business Purpose: Investor Beware

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Assume that X and Y agree to the following: X will transfer ownership of Prop to Y, and Y will transfer cash to X. What just happened? Obviously, X has sold Prop to Y. If the amount of cash that X receives is greater than...more

McDermott Will & Schulte

Court Rules Taxpayer Can Offset Foreign Tax Credits With NIIT Liability Under Tax Treaty

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In 2013, the net investment income tax (NIIT) found in Internal Revenue Code (IRC) Section 1411 went into effect. Since then, United States taxpayers residing outside of the US have lived with uncertainty as to whether the...more

ArentFox Schiff

Self-Directed IRAs and the Prohibited Transaction Rules

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In part 1 of this article, we reviewed the federal law on permitted investments for self-directed IRAs and the various tax, compliance and reporting rules that apply to individual retirement accounts (IRAs). Part 2 discusses...more

Coblentz Patch Duffy & Bass

Distinguishing Investment and Business Expenses - Family Office Structuring After Lender

Coblentz Patch Duffy & Bass on

Structuring a family’s investment activities can be complex. Across assets, activities, relationships and the particular circumstances of each family member-investor, a family office will typically provide a spectrum of...more

Polsinelli

Big Win for Investors Facing Listed Transaction Penalties for Conservation Easements

Polsinelli on

On November 9, 2022, in a 15-2 decision, the Tax Court held that the IRS improperly issued Notice 2017-10 in Green Valley Investors, LLC, et al. v. Commissioner of Internal Revenue, 159 T.C. No. 5. The Notice designated...more

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