Facts In 2001 Emilio Rodriguez was born and suffered some sort of tortuous injury for which he recovered over $400,000. Meanwhile his parents bought a small house but could not keep up the mortgage payments. His guardian, an accountant with 25 years … [Continue reading] about First Time Home Buyer Credit Economic Substance?
The same issue came before the Tax Court for later years. On appeal from the Tax Court, the Tenth Circuit has just reversed the Tax Court and come out on the opposite side of the critical issue from the Federal Circuit. 107 AFTR 2d 2011-XXXX (10th … [Continue reading] about Chevron Deference and the Salman Ranch
Facts Corp. A licensed certain technology to G (called Agreement A) in the past. It entered into a closing agreement with the IRS several years ago to treat Agreement A as a license. Later it modified Agreement A in Agreement B, under which Corp. A … [Continue reading] about Foreign Patent Commercialization
Although their application is wider, the single example is basically as follows: Example. USP owns US1, which owns FT with no gain or loss in the FT stock. USP also owns FS, which has lots of earnings and profits. FS buys USP stock in … [Continue reading] about “Killer B” Regulations Finalized
Georgia Tax Legislation Enacted in 2011 The Georgia General Assembly opened the 2011 legislative session with the goal of overhauling the state’s tax code, but it settled for passing only a handful of much less ambitious bills. By … [Continue reading] about Summary of 2011 Georgia Legislation and Reminder Regarding Georgia Property Tax Notices