The Tax Court in Brief – January 23rd – January 27th, 2023 Freeman Law’s “The Tax Court in Brief” covers every substantive Tax Court opinion, providing a weekly brief of Read more ››
Meiliyane Blog
The IRS and Abusive Trust Arrangements: Non-Grantor Trusts
Mr. Roberts is a Principal of the firm. He devotes a substantial portion of his legal practice to helping his clients successfully navigate and resolve their federal tax disputes, either Read more ››
Reviewing a Foreign Legal Structure
Why You Should Hire a Tax Professional to Review Your Foreign Legal Structure U.S. parented corporations that have foreign operations conducted through a foreign legal structure have significant U.S. tax Read more ››
Fraudulent Transfers | Insolvency | Freeman Law
So this is the fourth in my expected five-part series on fraudulent transfers. In previous blogs, I laid out the basic statutory framework regarding fraudulent transfers, as well as a Read more ››
Tax Court in Brief | Patacsil v. Comm’r | Insolvency to Avoid Recognition of Cancellation-of-Indebtedness income; Net Operating Loss; Reliance on Tax Professional
The Tax Court in Brief – January 16th – January 20th, 2023 Freeman Law’s “The Tax Court in Brief” covers every substantive Tax Court opinion, providing a weekly brief of Read more ››
S-Corporations | Involuntary Termination of the S-Election
Private Letter Ruling 202302004, 01/13/2023, IRC Sec. 1362 Summary: Entity “A” (“A”) was incorporated as a limited liability company under state law and thus was initially treated as a partnership Read more ››
Tax Court in Brief | Lucas v. Comm’r | Deficiency for Early 401(k) Distribution; 10% Additional Tax; Exclusion for “Unable to Engage in Any Substantial Gainful Activity
The Tax Court in Brief – January 16th – January 20th, 2023 Freeman Law’s “The Tax Court in Brief” covers every substantive Tax Court opinion, providing a weekly brief of Read more ››
Texas Law Update: Statute of Limitations, the Discovery Rule, and Fraudulent Concealment
On January 13, 2023, the Texas Supreme Court issued its opinion in Marcus & Millichap Real Estate Investment Services of Nevada, Inc. v. Triex Texas Holdings, LLC, __ S.W.3d __, Read more ››
Tax Court in Brief | Smith v. Comm’r | Exclusion of Value of Lodging Provided by Employer
The Tax Court in Brief – January 9th – January 13th, 2023 Freeman Law’s “The Tax Court in Brief” covers every substantive Tax Court opinion, providing a weekly brief of Read more ››
IRS CCMs on Crypto Donations and Crypto Losses
IRS Chief Counsel Memoranda: Cryptocurrency Donations Above $5,000 Need Qualified Appraisal and No Unrealized Cryptocurrency Loss Without Disposition Introduction The IRS recently released two chief counsel memoranda addressing cryptocurrency donations Read more ››