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April 14, 2021 | New York Law Journal

'Management Fee' Deductions Disallowed: 'Aspro v. Commissioner'

In this edition of their Taxation column, David E. Kahen and Elliot Pisem discuss a recent Tax Court decision disallowing deductions for purported management fees paid by a closely held corporation to its shareholders, in which the court concluded that the payments were disguised dividends and that the petitioner failed to establish that the payments were reasonable in relation to services rendered.
8 minute read
March 01, 2021 | New York Law Journal

'MarketShare' Acknowledges Challenge of Distinguishing Consulting, Information Services, and Software

As the world marches into the third decade of widely available electronic resources, distinguishing among consulting services, information services, and the provision of software, and then applying the differing sales tax rules to them, becomes only more difficult. In this edition of their Tax Appeals Tribunal column, Joseph Lipari and Aaron S. Gaynor discuss the recent determination in 'MarketShare Partners', which provides a rich text for those trying to classify a business as fitting into one of these categories.
8 minute read
February 23, 2021 | New York Law Journal

Treasury Issues Final Regulations on Carried Interest

On July 31, 2020, Treasury released proposed regulations under Section 1061, and on January 7, 2021, Treasury finalized these regulations. The final regulations largely adopt the proposed regulations, but with some important modifications that are largely favorable to taxpayers.
6 minute read
February 17, 2021 | New York Law Journal

Taxpayer Prevails on Substance Over Form: 'Complex Media v. Commissioner'

In their Taxation column, Elliot Pisem and David E. Kahen discuss 'Complex Media v. Commissioner', in which a corporate taxpayer that acquired a business in exchange for stock and other property prevailed over the IRS, on the basis of an argument that the substance of the transaction was different from its form, and was allowed to claim amortization deductions attributable to a basis step-up arising from the substance of the transaction.
10 minute read
December 22, 2020 | New York Law Journal

Treasury Issues Final Regulations Under Section 163(j)

On Nov. 26, 2018, the Treasury Department issued proposed regulations under Section 163(j), and on July 28, 2020, these regulations were finalized. The final regulations largely adopt the proposed regulations, but with some important modifications that are generally favorable to taxpayers.
6 minute read
December 16, 2020 | New York Law Journal

Tax Treatment of Damages for Accountant Malpractice: 'McKenny v. United States'

A taxpayer suffers a loss by reason of errors made by a tax advisor, and the tax advisor makes a payment to compensate the taxpayer for the loss. May the payment be excluded from the taxpayer's income subject to tax? In this edition of their Taxation column, David E. Kahen and Elliot Pisem discuss a recent decision in which the Eleventh Circuit court concluded that the taxpayers before it could not exclude the payment at issue from income.
8 minute read
October 20, 2020 | New York Law Journal

More Liabilities Please: The Allocation of a Partnership's Liabilities

In October, 2019, the Treasury Department finalized a set of regulations that will have an important impact on how liabilities are allocated when a partner guarantees partnership debt. In their Real Estate Financing column, Ezra Dyckman and Charles Nelson discuss the importance of the allocation of a partnership's liabilities.
5 minute read
October 14, 2020 | New York Law Journal

'Deckard': Failure to Establish Stock Ownership Defeats S Corp Shareholder Treatment

In their Taxation column, David E. Kahen and Elliot Pisem examine how an irregularity in corporate form may invalidate an election and give rise to adverse consequences that become apparent only in the context of a tax audit years after the election was attempted.
8 minute read
September 10, 2020 | New York Law Journal

'Mars' Highlights Limits of City Conformity to Federal Tax Principles

In their Tax Appeals Tribunal column, Joseph Lipari and Aaron S. Gaynor discuss a recent administrative law judge determination that highlights the question of whether and how federal tax principles apply to New York state and city taxes in situations other than an express decoupling.
7 minute read
August 25, 2020 | New York Law Journal

Not Getting Carried Away: Proposed Regulations on Carried Interest

In their Real Estate Financing column, Ezra Dyckman and Charles Nelson discuss the proposed Treasury regulations under Section 1061 which clarify provisions of the carried interest rules.
5 minute read

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