Tax Section

Section 1377(a)(2) Elections for S Corporations

Section 1377(a)(1) generally provides each shareholder of an S corporation is allocated income or loss of the corporation by (a) assigning an equal portion of…

Qualified Charitable Distributions from IRAs

Section 401(a)(9) requires annual minimum distributions from traditional IRAs beginning in the year the owner of the account attains age 72 or, if later, the…

Federal Income Tax Update

This is the last of three installments of this article. I. Bookkeeper Falls Victim to Section 6672 Trust Fund Recovery Penalty; Kazmi, TC Memo 2022-13. In…

New North Carolina PTE Tax Can Reduce Federal Income Taxes

The Tax Cuts and Jobs Act of 2017 capped the deduction available to individual taxpayers under Section 164 to $10,000 for 2017 through 2025. That deduction…

Federal Income Tax Update

This is the second of three installments of this article.  I. Contemporaneous Written Acknowledgment Rules for Charitable Contributions of Aircraft and…

Federal Income Tax Update

This is the first of three installments of this article.  I. Audit Statistics: What Are Your Chances of Being Audited? The 2021 Internal Revenue Service Data…

Transferee Liability Under Section 6901

In general, operating a business through an entity can provide limited liability in the event the entity is insolvent or goes out of business. Limited…

Taxation of Noncompete Agreements

Purchasers of a successful business have the reasonable concern that the prior owners will use their expertise to open a new business across the street that…

You Cannot be Both an Employee and a Partner of a Partnership

A person who is both an employee and a partner in a partnership is not treated as an employee for tax purposes. Rev. Rul. 69-184 states “bona fide members…

Wells Hall Becomes Chair of the ABA Section of Taxation

Our colleague Wells Hall is now the chair of the ABA Tax Section. Congratulations Wells! Wells is an attorney with Nelson Mullins and a long-time mainstay of…