Category Archives: Federal Tax Advisory

Federal Tax ADVISORY: Partial Worthlessness

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Don’t overlook claiming a deduction for partial worthlessness. Our Federal Tax Group provides a refresher on this useful tool.

  • Cross-border or brother-sister debt
  • A hard pill to swallow
  • Ordinary loss

Read the full advisory here.

Federal & International Tax ADVISORY: Big Tax Court Win for Foreign Investors in U.S. Partnerships

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Our Federal & International Tax Group examines the long-awaited decision in Grecian Magnesite Mining, Industrial & Shipping Co., SA v. Commissioner. While a win for foreign investors in U.S. partnerships, it may not be the final word. Repudiates decades-long position of IRS May have a real impact on U.S. foreign investment May not be the last word on the subject Read the full advisory here. [...]Read more

Federal Tax ADVISORY: Taxpayer Wish List

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The Treasury is open for business to change tax rules to ease your compliance burdens. Our Federal Tax Group points out a few regulations that could use some updating. Reduce red tape Regulations can ease the burden What's on your list? Read the full advisory here. [...]Read more

Federal Tax ADVISORY: Fourth Circuit Economic Substance Doctrine

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The Tax Court takes on the Fourth Circuit's version of the sham transaction doctrine. Our Federal Tax Group considers the implications going forward. The Tax Court said no The peculiar things about the opinion The takeaway Read the full advisory here. [...]Read more

Federal Tax ADVISORY: Mutual Company Reorganizations

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Our Federal Tax Group warns that voting stock can pop up in unexpected forms, even in bank mergers.
• Mutual corporation mergers
• Voting rights as continuing equity
• The value of voting interests

Read the full advisory by clicking here. 

Federal Tax ADVISORY: A Niche Tax: The Firearms Taxes

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Our Federal Tax Group offers a rundown of the sometimes confusing laws governing firearms taxes not administered by the IRS.

  • Manufacturers excise tax
  • National Firearms Act taxes
  • Gun Control Act fees

Read the full advisory by clicking here.

International Tax ADVISORY: Section 721(c) Partnership Regulations Arrive Just in Time

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On January 18, 2017, the IRS issued temporary and proposed regulations (T.D. 9814) under section 721(c) to address transfers of appreciated property by U.S. persons to partnerships with related foreign partners. With some alterations, these regulations deliver on guidance announced in Notice 2015-54, released in August 2015 (see our prior coverage of Notice 2015-54 here). The regulations incorporate a number of taxpayer-friendly updates in response to comments on the Notice. The prospect of further direction in this area, however, including guidance under Sections 482 and 6662 as described in the [...]Read more

Federal Tax ADVISORY: Predecessor and Successor Regulations

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There are still many questions about the meaning of the Treasury’s new regulations applying Section 355(e) to predecessors and successors. Our Federal Tax Group examines the answers we do have and what they mean for practitioners.

Read the full advisory here. 

Federal Tax Advisory: Stock Dividend Foot Faults

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Beware of the unexpected application of Section 305 to your stock distributions. Our Federal Tax Group serves up examples of useful tools to use.

Read the full advisory by clicking here.