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Business Tax

IRS Stops Deductions on Start Up Expenses in Some Partnership Terminations

May 17, 2017

When partnerships are formed, the owners typically pay out start-up and organizational expenses such as advertising costs, travel expenses, legal fees and filing fees. Although small partnerships may immediately deduct up to $5,000 of these expenses, larger entities must amortize... Read More

Taxpayers Lose Jobs Credit and Sales Tax Disputes Before Georgia Tax Tribunal

March 24, 2017

In 2012, the Georgia Legislature created the Georgia Tax Tribunal, a specialized court to hear tax disputes between taxpayers and the Georgia Department of Revenue (DOR). Hearings are before one judge with no jury trials. The creation of the Tribunal... Read More

Gift Arose from Merger of Family Corporations

March 6, 2017

The long saga of couple William and Patricia Cavallaro’s gift tax fight with the IRS is not over yet but is closer to being resolved. A federal appeals court has upheld the IRS’s characterization of the merger of their company,... Read More

Shifting Gain to Foreign Partners More Difficult Under New IRS Rules

February 20, 2017

Almost 20 years after Congress gave the IRS specific authority to act, the IRS has developed a plan to prevent U.S. taxpayers from shifting gain to foreign partners. In short, the benefits of forming international partnerships could be diminished by... Read More

Expensing More Popular Than Bonus Depreciation, Treasury Study Shows

December 28, 2016

Even though businesses claim over $300 billion a year in Section 179 expensing and bonus depreciation deductions, only 40-60 percent of eligible firms use bonus depreciation. A recent Treasury study attributes this “under- utilization” to firms being in a loss... Read More

Restaurant Franchisee’s Novel Argument to Avoid Self-Employment Tax Fails

November 22, 2016

You have to hand it to taxpayers to come up with clever ideas to avoid tax. The problem is, they rarely work in an area of settled law, such as self-employment tax on partnership earnings. Case in point: An LLC... Read More

Georgia Update: Jobs Credit for Disregarded Entities, Sales Tax Disclosure

November 22, 2016

Issues with the application of the quality jobs tax credit have been keeping the Georgia Department of Revenue (DOR) busy. Within the last year, the credit has been amended by the Georgia legislature and has been the subject of several... Read More

Estate Allowed to Deduct LLC Losses from Madoff Ponzi Scheme

October 31, 2016

ESTATE WINS NOVEL DEDUCTION FROM MADOFF PONZI LOSSES It has been over eight years since Bernie Madoff was caught running perhaps the biggest investment fraud scheme in U.S. history, but the tax fall-out still continues. In a “case of first... Read More

Georgia Quality Job Tax Credit is Not Transferable

August 5, 2016

Tax credits are understandably of interest during the sale of a company. That said, it is important to understand if they are transferrable to the new company. Imagine this scenario. A successful plant in Georgia creates new jobs and qualifies... Read More

IRS Backs Off on Bad Boy Guarantees

May 24, 2016

Following pressure by tax practitioners and the real estate industry, the IRS has backed off its position that common “bad boy” guarantees can result in restricted loss deductions for investors in real estate limited partnerships and limited liability companies. As... Read More

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