Tax Section

Exclusions to the Net Investment Income Tax

Since its enactment on March 30, 2010, in connection with the Affordable Care Act, Section 1411 has assessed an additional 3.8% income tax on individuals,…

Federal Income Tax Update

1. Taxpayer Denied a Bad Debt Deduction even though the Borrower had Cancellation of Debt Income; Kelly v. Commissioner, 139 F.4th 854 (9th Cir. 2025).…

Installment Sale Notes Owned by S Corporations

When an S corporation sells its assets, often part of the purchase price is paid via a promissory note issued by the buyer. These promissory notes are part of…

The Spirit of Giving: NCBA’s New U.S. Tax Court Calendar Call Program

Of the three forums for judicial review of a federal tax dispute, only the Tax Court is a pre-payment forum, meaning a taxpayer can have a tax case heard by…

Unreimbursed Expenses of Employees and Partners

The 2017 Tax Cuts and Jobs Act included Section 67(h), which eliminated miscellaneous itemized deductions for tax years beginning after December 31, 2017. The…

Remembering Steve Horowitz, 1990-1991 Chair of the Tax Section

It is with deep sadness that we share the news of the passing of Steven (“Steve”) Horowitz, a former Chair of our Section (1990–1991) and a respected…

Recovering Costs and Attorney Fees From the IRS: The Qualified Offer Rules

The Qualified Offer rules are part of the broader framework for resolving federal tax disputes. As a general rule, taxpayers who prevail in disputes with the…

Welcome from the Tax Section Chair – Introducing Our 2025-2026 Leadership Team

Dear Tax Section Members, I am honored to serve as Chair of the North Carolina Bar Association Tax Section for the 2025-2026 year. Our Section continues to…

Publicly Traded Partnerships

Section 7704 provides a partnership is a publicly traded partnership if interests in the partnership are (1) traded on an established securities market or (2)…

What is a QSub?

As discussed in my February 2025 blog post Eligible S Corporation Shareholders, corporations generally cannot own the stock of S corporations, even if the…