Expanded Benefits for Qualified Small Business Stock Under the OBBB
The gain exclusion benefits for the sale of qualified small business stock (“QSBS”) have grown in popularity in recent years, in part due to the 2017 Tax…
Federal Income Tax Update
I. 2024 IRS Audit Statistics. The 2024 IRS Data Book released in April 2025 contains audit statistics for years 2014 through 2022, as of the fiscal year ended…
Classification of LLCs Under the Check-the-Box Regulations
Limited Liability Companies (or LLCs) were invented in Wyoming in 1977. They have since spread to all states and become one of the most popular entities to…
Disallowance of Deductions or Credits Under Section 269
Section 269(a) applies where a “person or persons acquire, directly or indirectly, control of a corporation” and “the principal purpose for which such…
Federal Income Tax Update
I. Real Property Distributed from Testamentary Trust Meets the Section 1031 “Held for Investment” Requirement; PLR 202449007. A testamentary trust…
Federal Income Tax Update
I. IRS Cannot Impose Tax on Withdrawals from an IRA It Seized; Hubbard v. Commissioner, 135 AFTR 2d 2025-484 (6th Cir). Mr. Hubbard was a Kentucky pharmacist.…
Carried Interest Holding Period Under Section 1061
Enacted in 2017, Section 1061 provides a minimum holding period of three years for long-term capital gains for carried interests issued to certain service…
Attend the 24th Annual North Carolina Tax Section Workshop
I hope this message finds you well. As we approach Memorial Day, I want to personally encourage you to attend the 24th Annual North Carolina Tax Section…
Meaningless Gesture Doctrine Under Section 351
Section 351(a) provides no gain or loss is recognized if property is transferred to a corporation by one or more persons solely in exchange for stock in such…
Potential Gain Due to Assumption of Liabilities by Corporation
A taxpayer’s relief from indebtedness is generally a taxable event. However, where Section 351 applies to a contribution of assets to a corporation for…