It is commonly known that sales of partnerships can give rise to ordinary income (subject to a current maximum tax rate of 39.6%) and long-term capital gain (subject to a current maximum tax rate of 20%). This is true...
At the close of 2016, the IRS’ contempt for syndicated conservation easement deals reached its peak with the IRS identifying such transactions as “listed transactions.” See prior MC Talks Tax blog post here. By...
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...
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...
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