Tax Section
Assignment of Income Doctrine
The assignment of income doctrine was established in Lucas v. Earl, 281 U.S. 111 (1930). It is a judicial doctrine that requires income earned by a taxpayer…
Basics of Section 409A
Section 409A addresses the taxation of nonqualified deferred compensation plans. A nonqualified deferred compensation plan is any arrangement that provides…
Taxation of Cooperatives Under Subchapter T
Tax practitioners are familiar with Subchapter C (C corporations), Subchapter K (partnerships), and Subchapter S (S corporations) but are generally less…
Welcome to the 2024-2025 Tax Section Year!
I trust everyone is having a good summer and finding enjoyable ways (aside from work) to avoid the heat and the daily downpours. We were fortunate this year…
Federal Income Tax Update
I. Thanksgiving Holiday Extends the Due Date for Filing Tax Court Petition; Sall vs. Commissioner, 161 T.C. No. 13 (2023). Mr. Sall received a notice of…
Section 351
Section 1032 provides no gain or loss is recognized by a corporation on the issuance of its stock to a new owner, whether in exchange for cash or otherwise.…
Federal Income Tax Update
I. 2023 Audit Statistics; Chances of Being Audited. The 2023 Internal Revenue Service Data Book released in April 2024 contains audit statistics for years…
Section 754 Elections
A partnership may elect to adjust its inside basis under Sections 734(b) and 743(b) by making a Section 754 election with the partnership’s annual tax…
Transfers of Property Between Divorcing Spouses
Prior to the Tax Cuts and Jobs Act of 2017, transfers between spouses or former spouses incident to divorce were treated as either (a) nontaxable transfers…
Jack Cummings Receives Tax Notes’ Award for Excellence in Tax Commentary
Jack Cummings received Tax Notes’ inaugural Award for Excellence in Tax Commentary on May 3 at the ABA Tax Section’s annual meeting. Jack is counsel in…