Sec. 1202 offers a compelling tax benefit: exclusion of up to 100% of the gain from the sale of qualified small business stock (QSBS) that has been held for at least five years. For eligible taxpayers ...

Sec. 1361 sets forth the basic qualifications for S corporation status. Among the most important are the limitation on types of shareholders and restrictions to a single class of stock. Tax Court ...

In a recent development following a series of legal actions, e.g., House v. NCAA 5 and Carter v. NCAA, 6 a settlement agreement was reached between the college sport stakeholders, including the NCAA, ...

Profits–interest partners frequently are allocated a share of the gain recognized in connection with a liquidity event. This allocation can lead to unexpected results related to Sec. 1245 recapture.

Under Sec. 6501(a), the IRS generally has three years after the return is filed to assess tax, but there are several exceptions. For example, the assessment period may be extended by mutual agreement ...

The Eighth Circuit, affirming a district court, held that because a wife had no property interest in a home owned by her husband that was sold in a judicial sale to satisfy his federal tax debts, she ...

Equitable tolling can apply to a petition challenging an IRS employment status determination under Sec. 7436. However, it does not apply where a petition was one day late because the taxpayer’s ...

CPAs who practice in public accounting provide myriad services, such as external auditing, tax compliance, and tax representation. To promote ethical behavior in the accounting profession, CPAs must ...

David is a trusted advisor to ultra-high-net-worth individuals, business owners, and multigenerational families, specializing in wealth strategies that preserve and grow wealth. He is especially ...

Investments in energy projects offer two primary tax benefits: the ITC and accelerated depreciation. Some developers cannot use these tax benefits themselves but can use them to incentivize tax equity ...

1. Once the president of the United States declares a federal disaster, the IRS has discretion to provide tax relief for numerous taxpayer deadlines. Congress has given the IRS authority to postpone ...