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IRS Extends Section 1031 Deadlines Due to Hurricane Ida
In their Real Estate Financing column, Ezra Dyckman and Charles Nelson discuss the Hurricane Ida relief issued by the IRS which may provide a significant benefit to certain taxpayers in the NYC area that are engaging in Section 1031 exchanges, however they warn that the consequences of failing to meet a Section 1031 deadline are severe.
Recharacterization of Debt as Equity: 'Tribune Media'
In this edition of their Taxation column, Elliot Pisem and David E. Kahen discuss a recent decision in which the Tax Court determined that the Ricketts family's investment, although documented as subordinated debt, was properly characterized as "equity" for tax purposes, such that the deferral sought by Tribune Media was unavailable.
Domicile Determination Involving Dementia Patient
In this edition of their Tax Appeals Tribunal column, Joseph Lipari and Ellen S. Brody discuss a recent Surrogate's Court case, 'Matter of Estate of Matarazzo', which addressed whether a person with dementia can form the requisite intent to change domicile. Interestingly, the issue arose not in connection with a personal income tax audit, but in the context of a probate proceeding.
'Kelly v. Commissioner': Loans Recharacterized as Distributions
In this edition of their Taxation column, Elliot Pisem and David E. Kahen discuss the recent Tax Court decision in 'Kelly v. Commissioner', which deals with the recharacterization of purported loans made between affiliates as shareholder distributions, and potential consequences for failure to file a Form 5471 in the context of a foreign corporation owned by a U.S. person.
'Misrahi' a Reminder That Form Matters in Affiliate Transactions
There is often "a degree of casualness" in the case of transactions between affiliated parties, and that casualness can lead to unexpected tax consequences. In this edition of their Tax Appeals Tribunal column, Joseph Lipari and Aaron S. Gaynor discuss a recent Division of Tax Appeals determination, which engages with similar issues in the income tax context, and serves a reminder that good form matters.
Transaction 'Integration': 'GSS Holdings (Liberty) v. United States'
In this edition of their Taxation column, Elliot Pisem and David E. Kahen discuss 'GSS Holdings (Liberty) v. United States', a recent decision of the Court of Federal Claims that discusses (1) the scope of what is sometimes referred to as the 'Danielson' rule, and (2) substance over form and transaction integration principles in the context of multiple payments that were ultimately integrated for tax purposes by the court into a single transaction.
Help Is On the Way: New York Enacts Pass-Through Entity Tax
In their Real Estate financing column, Ezra Dyckman and Charles Nelson discuss New York's new pass-through entity tax regime which can provide a significant federal tax benefit to businesses owned through pass-through entities, such as real estate and other closely held businesses, however taxpayers need to be aware of several uncertainties and complexities regarding the application of the new law.Equitable Estoppel Blocks Taxpayer: 'New Capital Fire v. Commissioner'
In this edition of their Taxation column, David E. Kahen and Elliot Pisem explore a case in which a taxpayer's current position was preluded on the ground of equitable estoppel, as it was inconsistent with the taxpayer's prior position.
Recent Case Demonstrates Difficulties in Changing Domicile
Due to the pandemic, many New Yorkers are moving out of the city. Citing the recent decision in 'Boniface,' Joseph Lipari and Ellen Brody, in their Tax Appeals Tribunal column, discuss the difficulties most individuals will face in carrying out this change of residency.
IRS Requires Reporting of Tax Basis Capital Accounts
In their Real Estate Financing column, Ezra Dyckman and Charles Nelson discuss the new 2020 partnership tax basis capital account reporting requirements which "give the IRS much more visibility into the tax situations of partners in partnerships."TRENDING STORIES
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