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Don’t Forget Ruling Guidelines

August 3, 2020 By Jasper L. (Jack) Cummings, Jr.

Take a trip down memory lane as our Federal Tax Group leads you through past IRS ruling guidelines still in effect. Rev. Proc. 2020-1 is a good reference for effective ruling guidelinesEven old ruling guidelines can apply to a “significant issue”Don’t assume there isn’t an IRS ruling guideline Read the full advisory here. [...]Read more

Filed Under: Federal Tax Advisory Tagged With: dividend, IRS, spinoffs, stock

Book Value Sales

December 1, 2017 By Jasper L. (Jack) Cummings, Jr.

Our Federal Tax Group explores how affiliates selling property to each other at book value could cause more problems than it solves.

  • Book value
  • Fair market value
  • The tax consequences

Read the full advisory here.

Filed Under: Federal Tax Advisory Tagged With: book value, dividend, section 482, shareholders, stock, subchapter C

Federal Tax Advisory: Stock Dividend Foot Faults

January 3, 2017 By Jasper L. (Jack) Cummings, Jr.

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. 

Filed Under: Federal Tax Advisory Tagged With: Class A Common, class B common, common stock, convertible debt, dividend, Section 305, Section 6045B, stock, stock distribution, stock dividend food faults, Treasury

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