Tax Law

Recent Posts

Additional First-Year Depreciation for Certain Property
Posted on 25 Mar 2011 by Gerald W. Paulukonis, J.D.

An additional first-year depreciation deduction equal to 50 percent of the adjusted basis of qualified property is allowed for qualifying property that is acquired during calendar years 2008 through 2012. The additional first-year depreciation deduction... Read More

Weaknesses in Federal and State Tax Incentives for Renewable Energy
Posted on 29 Sep 2008 by Gail H. Morse and Alexandra E. Dowling

In this Emerging Issues Commentary, Gail H. Morse and Alexandra E. Dowling of Jenner & Block’s Chicago office trace the history of federal and state tax incentives, starting with early federal tax incentives in 1916 for fossil fuel production... Read More

Disposition of Less Than the Whole: The Need to Identify the Securities Sold
Posted on 19 Aug 2010 by LexisNexis Tax Center

Authored by Andrew W. Singer Beginning January 1, 2011, brokers previously required to report to the Internal Revenue Service the gross proceeds from sales of stock by their customers are also required to report the adjusted basis of the stock sold... Read More

Important New DOD Reg on Internal Controls for Contractor Business Systems
Posted on 12 Jul 2011 by Darrell Oyer

The Department of Defense (DOD) has promulgated DFARS 215.407-5-70 that demands almost perfect internal control for contractor business systems and includes significant sanctions and penalties for failure to comply. Failure to comply with the regulation... Read More

Collateral Consequences of Engaging in Tax Avoidance Transactions
Posted on 1 Feb 2012 by LN Tax Law Staff

By Andrew W. Singer, Esq. * ... Due to a growing tax shelter industry and tax advisors aggressively selling problematic schemes that promise to reduce the tax liability of the wealthy individuals and major corporations that utilize them, Congress... Read More

Exclusion for Sale of Qualified Small Business Stock Increased
Posted on 1 Sep 2009 by Philip R. Fink, J.D.

IRC Section 1202(a)(3) was added by the American Recovery and Reinvestment Act of 2009 (“the Act”). It encourages individuals to make investments in corporations by allowing them to temporarily exclude a greater amount of the gain on the sale... Read More

New Guidance on Executive Compensation Limits
Posted on 18 Jun 2009 by Jayne Zanglein

On June 9, 2009, the Department of the Treasury issued an interim final rule on TARP Standards for Compensation and Corporate Governance. The rule provides guidance on the executive compensation and corporate governance provisions of the Emergency Economic... Read More

Drafting Target Partnership Allocations When Nonrecourse Liabilities Are Present
Posted on 5 Nov 2009 by USC Gould School of Law

A challenge encountered by tax practitioners when attempting to draft target partnership allocations is how to deal with nonrecourse liabilities. The target allocation provision may satisfy the nonrecourse deduction safe harbor if allocations under the... Read More

Taxation of Short Sales and Foreclosures
Posted on 16 Sep 2010 by Mark S. Ericsson

Short sale and foreclosure tax inquiries focus on how much gain and cancellation of indebtedness (COD) to recognize. Gain is the amount realized over the amount invested. Net worth increase is income realized, unless statutory or case law allows exclusion... Read More

Obama Tax Policy: Meeting Economic Crisis Challenges
Posted on 4 Feb 2009 by hdr

If there is one word that has characterized the campaign of President Obama that word is "change." So it seems a fair question to ask what the new Administration might have in mind, or could have in mind, or should have in mind, by way of change... Read More

"Disregarded Entity" Hazard Compels Consideration of "Checking the Box"
Posted on 16 Oct 2008 by Rufus Rhoades

Rufus v. Rhoades, Esq., co-author of the treatise Rhoades & Langer, U.S. International Taxation and Tax Treaties , analyzes "disregarded entities" in the international context and reminds you to consider checking the box to save taxes. The... Read More

Acquisitions Using Tax Partnerships - Maximizing the Rules for Amortizing Intangible Assets
Posted on 28 Sep 2009 by USC Gould School of Law

Summary : A businesss goodwill and going concern value or other intangibles are often its most valuable assets. The interaction of the rules concerning acquisitions using tax partnerships and the Section 197 rules for transferred intangibles are addressed... Read More

2009: The Year of Enforcement Action Against Offshore Bank Accounts
Posted on 6 Oct 2009 by Fran Obeid

SUMMARY : There are a number of reporting obligations that must be complied with to avoid criminal and civil penalties in connection with foreign bank accounts. This year, the IRS, Department of Justice, President Obama and Congress have prioritized enforcement... Read More

U.S. Citizens Abroad - IRC Section 911
Posted on 4 Sep 2009 by Rufus Rhoades

Rufus v. Rhoades reviews the rules which apply to U.S. citizens and residents who live abroad for one year or more, and it discusses eligibility for benefits under IRC Section 911, the amount that is excludable from gross income, the housing cost allowance... Read More

Effective Roth IRA Conversions for 2010
Posted on 9 Feb 2010 by Philip R. Fink, J.D.

Until 2010, individuals with a modified adjusted gross income in excess of $100,000 could not convert their traditional IRAs or 401(k) plans to a Roth IRA. For years after 2009, all taxpayers regardless of income can make the conversion. However, for... Read More