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Internal Revenue Service Tax Liability Loans

The United States Internal Revenue Service is a bureau of the United States Department of the Treasury. The IRS is charged with collecting revenue and enforcing the Internal Revenue Code.  
Troutman Pepper Locke

Section 899 Implications for Foreign Banks Lending to US Borrowers through US Lending Offices

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In an earlier alert, we described the potential impact of the One Big Beautiful Bill on withholding taxes imposed on loans made by foreign banks to U.S. borrowers. ...more

Warner Norcross + Judd

The Powers and Perils of Intrafamily Loans

It is not uncommon for family members to lend a helping hand to one another through intrafamily loans. While loans can benefit family borrowers who may not qualify for a traditional loan or who need flexible payment...more

Pillsbury Winthrop Shaw Pittman LLP

Norwich v. Comm’r: Private Credit Firm Prevails in Tax Dispute to Reverse Over-Reported Income

In Norwich v. Comm’r, the taxpayer mistakenly received $7.5 million[2] as a result of various bank errors between 2007 and 2014. Not knowing that the cash was incorrectly released to it, the taxpayer reported those amounts as...more

Farella Braun + Martel LLP

Insider Transaction Traps for the Unwary

Welcome to EO Radio Show - Your Nonprofit Legal Resource. I'm Cynthia Rowland, and today I'm joined by David Sacarelos, a principal at Baker Tilly. We do a deep dive into the penalties under the Internal Revenue Code sections...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

Business Owner Borrows from Their Private Foundation – A Different Form of “For Profit Philanthropy”?

Rivkin Radler LLP on

Many successful business owners attribute some part of their success to their community. For some of these owners, it is not enough to simply acknowledge this “debt”; they feel an obligation to share some of their financial...more

Cadwalader, Wickersham & Taft LLP

Exchange Trust Certificates in REMIC Transactions Qualify as Stripped Bonds or Coupons

On November 24, 2023, the IRS released PLR 202347001, ruling that certificates issued from an “exchange trust” qualify as stripped bonds or stripped coupons within the meaning of Code Section 1286. The taxpayer in the...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

Trump’s Returns and Congress – Lessons, Next Steps?

Rivkin Radler LLP on

Last Friday, December 30, 2022, during the final hours of the 117th Session of Congress, the House Ways and Means Committee – through which all tax legislation passes – released redacted versions of six years of Mr. Trump’s...more

Rivkin Radler LLP

Bona Fide Intercompany Loan – Are You Sure?

Rivkin Radler LLP on

Head-Scratchers- The Code is chock-full of provisions that will challenge the intellectual capacity, not to mention the patience, of most tax professionals. The complexity of these rules does not arise out of some sadistic...more

Troutman Pepper Locke

When Does a Loan Guarantee Provide Amounts at Risk - Tax Update, Volume 2020, Issue 3

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In Bordelon v. Commissioner, the Tax Court addressed the circumstances under which an individual’s personal guarantee of a loan to his single-member LLC established sufficient amounts at risk to enable him to claim more than...more

Farrell Fritz, P.C.

Business Resources and Recovery (UPDATED)

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Businesses grappling with the economic impact of the ongoing COVID-19 crisis have the opportunity to apply for financial assistance through a variety of Federal, State and Local programs. ...more

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