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Earlier this month, the Fifth Circuit Court of Appeals had occasion to decide the applicability of the “self-rental rule” in Treas. Reg. § 1.469-2(f)(6) in the context of a Subchapter S corporation renting commercial...

In the right circumstances, a taxpayer may be able to significantly reduce his/her federal income tax liability from the sale of his/her business by establishing that the buyer separately bargained for the purchase of that...

The IRS issued Notice 2016-19 (here), effective February 11, 2016. The notice extends the filing deadline for the new Form 8971 to March 31, 2016.  As discussed in last week’s post, Form 8971 implements basis...

Conventional wisdom is that the U.S. income taxation of partnerships is advantageous compared to the taxation of corporations for many reasons, one of which is that it is often easier to contribute “built-in” gain...

On Jan. 29, 2016, the Internal Revenue Service released Form 8971, “Information Regarding Beneficiaries Acquiring Property From a Decedent” (here) with instructions (here). The form must be filed by any estate with an...