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Investment Tax Liability 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

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

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

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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

Coblentz Patch Duffy & Bass

Distinguishing Investment and Business Expenses - Family Office Structuring After Lender

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

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