Last year IRS Chief Counsel declared that a “partnership is not a corporation” and that the “wage and reasonable compensation rules which are applicable to corporations…do not apply.” Therefore once a partner is no...
The IRS is stacking-up victories in its attack against compensation arrangements of closely-held business, with C corporations, S corporations, and partnerships all potentially facing an IRS challenge. Now is the time to...
An Issue for Real Estate Developers and Their Tax Advisors to Keep An Eye On
April 19, 2017
By Joel N. Crouch, Blog
On April 10, 2017, the IRS Chief Counsel’s Office issued an Action on Decision (AOD 2017-3) (here) refusing to acquiesce to the Tax Court’s and 9th Circuit’s decisions in Shea Homes Inc. v. Commissioner, 834 F.3d...
The Government Settlement Transparency & Reform Act (S.803): Are the Tax Benefits of Corporate Settlements in Jeopardy?
April 6, 2017
On April 3, 2017, Senators Jack Reed (D-RI) and Chuck Grassley (R-Iowa) introduced bipartisan legislation that may impact or deny tax deductions for settlement payments regarding corporate regulatory violations. In recent...
TIGTA Report: The IRS Putting Innocent Small Business Owners at Risk in Currency Structuring Seizures and Forfeitures
April 5, 2017
By Joel N. Crouch, Blog
On March 30th, the Treasury Inspector General for Tax Administration (TIGTA) released a report titled “Criminal Investigation Enforced Structuring Laws Primarily Against Legal Source Funds and Compromised the Rights of Some...