Last month, I blogged on the IRS’ identification of Code Section 831(b) micro captives as “transactions of interest,” which triggered an obligation by taxpayers and material advisors to formally disclose the details of...
IRS Finalizes Documentation Requirements for Related-Party Debt: The Regulations and Their Effect on Closely-Held Corporations
In October of 2016, the IRS issued final regulations under IRC code section 385. The final regulations cover a number of issues under Internal Revenue Code (“IRC”) section 385. IRC section 385 deals, in general, with...
The IRS Adds Conservation Easements to the List of Tax Avoidance Transactions
On December 23rd the IRS issued Notice 2017-10 (here), which adds syndicated conservation easements to the category of transactions that require formal disclosure by investors and advisors to the IRS. Any taxpayer or...
Ethical Reminders from the Conviction of Paul Daugerdas
Aaron Borden wrote an article for the Ethics Column of the Dallas Bar Association Headnotes publication titled, “Ethical Reminders from the Conviction of Paul Daugerdas in the January 2017 issue. Click here to...
2016 Year-End Estate Planning (Video Included)
Now is the time to engage your clients in a discussion regarding the status of their estate planning. Many items must be completed before year-end or they will be lost. Others simply need attention on an annual basis....