Shareholders, Tax Liability, Tax Court

N.J. Appellate Division Affirms Tax Court, Denies Taxpayer’s Statute of Limitations Argument Regarding Responsible Person Tax...

McCarter & English, LLP on 2/26/2025

On February 5, 2025, the New Jersey Appellate Division released a decision in the matter of Christopher Gill v. Director (Docket No. A-3116-22), affirming the tax court’s holding that the state is not subject to a separate...more

A Journey Through Subchapter S / A Review of The Not So Obvious & The Many Traps That Exist For The Unwary: Part XIV – An S...

Foster Garvey PC on 1/23/2025

In this Part XIV of my multi-part series on some of the not-so-obvious aspects of Subchapter S, I explore a narrow aspect of Subchapter S that is often ignored or forgotten. An S corporation is not always a mere extension of...more

Shareholder-Transferee Liability for a Corporation’s Income Tax

Rivkin Radler LLP on 2/15/2024

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

Corporate Tax Hike On The Horizon: Using Reasonable Compensation To Withdraw Value

Farrell Fritz, P.C. on 3/9/2021

Corporate Rate Increase? We begin this week with the Senate having passed the President’s $1.9 trillion coronavirus relief and economic stimulus plan (the “American Rescue Plan” following a marathon session during which...more

Who Is The Taxpayer?

Farrell Fritz, P.C. on 1/3/2017

Back to Basics - This is not a silly question. In fact, it is often one of the most difficult issues confronted by a tax adviser, and it arises from one of the most basic of tax principles; specifically, that income is...more

Transferee Liability: The [Unlikely] Situation that your Nonprofit Receives a Charitable Gift with Expensive Tax Strings Attached

Coblentz Patch Duffy & Bass on 10/12/2016

The case of Salus Mundi Foundation et al v. Commissioner - On August 15, 2016, the Tax Court decided in Salus Mundi Foundation et al v. Commissioner, T.C. Memo. 2016-154, that two foundations were liable as transferees...more