ESBTs and the Carryover of S Corporation Losses
September 21, 2023 | Louis Vlahos | Business
Toll the Bells Since 1995 to the present, the LLC has emerged as the entity of choice for the vast majority of entrepreneurs. This form of business entity owes its success to the flexibility and to the tax benefits that it affords its members.[i] For example, there are no restrictions…
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Self-Employment Tax and the Limited Partner – Substance Over Form, or Something Else?
September 14, 2023 | Louis Vlahos | Federal | Income Tax
“Once More Into the Breach”[i] Last week, the IRS announced “the start of a sweeping, historic effort to restore fairness in tax compliance by shifting more attention onto high-income earners, partnerships, large corporations and promoters abusing the nation’s tax laws.”[ii] The IRS added that its efforts “will be driven with…
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Withholding Taxes: Deferred Comp and Services Overseas
September 06, 2023 | Louis Vlahos | Business | Federal | Income Tax
Approaching Year End Which holiday do you dread the most? For me, it has always been, and likely will always be, Labor Day. Of course, with each passing year, anything that I describe as “always” is less meaningful than it was the year before, at least to the extent it…
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Tax Compliance: Self-Assessment, Transparency, and Enforcement
August 23, 2023 | Louis Vlahos | Business | LLCs | Tax Compliance
NY’s Almost There Back in June of this year, New York’s legislature passed a bill that, if enacted, would create the first state-level public database with information regarding the ownership of limited liability companies (LLCs).[i] Beneficial owners are of interest to governments, including taxing authorities, because of their economic status…
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Sale of Mortgaged Property – Amount Realized or COD Income
August 16, 2023 | Louis Vlahos | Real Estate
What’s Next? Do you feel as challenged as I do when someone asks you to explain the term “Bidenomics”?[i] I know that it is predicated upon the imposition of higher taxes on businesses and their owners, which have not yet materialized.[ii] However one defines it, the White House tells us…
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Transferee Liability for Estate Tax: The Downside of Being a Beneficiary
August 10, 2023 | Louis Vlahos | Estate
Death of a Parent In the context of a family-owned business, it is often the case that the matriarch or patriarch of the family is also the chief executive of the business. They may have founded the business, or they may have been at its helm for longer than most…
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Should Closely Held Businesses Be Charitable?
August 03, 2023 | Louis Vlahos | Business
Faulty Framework? The question posed above is not intended to be rhetorical. Rather, it is one that the owners of a closely held business should consider thoroughly before transferring or committing any business assets to a charitable organization. Unfortunately, many owners fail to treat their business as a separate person.…
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Partnership Losses But No Outside Basis? Too Bad
July 26, 2023 | Louis Vlahos | Business
Losses Weren’t Always Bad Most tax advisers are aware that, prior to the Tax Reform Act of 1986 (the “TRA”),[i] the Code placed few limitations on the ability of an individual taxpayer to use deductions from a particular activity to offset income from other activities. In the absence of such…
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Debt or Equity? The Never-Ending Question For Closely Held Businesses
July 19, 2023 | Louis Vlahos | Business
What Was Intended? Transactions between commonly controlled, closely held businesses are often conducted in an informal manner. This is unfortunate because, in the absence of documentation, it is sometimes difficult to discern the parties’ intent with respect to a transaction. This may be especially troublesome for the businesses and their…
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Enough Already – Eliminate Downward Attribution and Accidental CFCs
July 11, 2023 | Louis Vlahos | Uncategorized | Congress | Foreign Income Sources | Foreign Taxes
It’s Complicated The Code includes a number of complex rules that are aimed at those overseas business and investment activities of U.S. taxpayers that Congress has determined may result in the improper deferral or avoidance of U.S. income tax. Because these business or investment transactions may involve convoluted capital or…
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