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On March 5, 2020, the Internal Revenue Service (“IRS”) and the U.S. Department of Justice (“DOJ”) announced that Mr. Oleg Tinkov was arrested in London in connection with an indictment concerning concealment of about $1 billion in foreign assets and the expatriation income in connection with these assets. Let’s discuss the Tinkov case in more […]
In a previous article, I discussed the IRC (Internal Revenue Code) §318 sidewise attribution limitation. This limitation was the last piece in the jigsaw puzzle of the §318 entity-member attribution rules; now, we are ready to summarize these rules in light of this exception. This is the purpose of this article – state the §318 […]
On April 9, 2020, the IRS announced additional relief to taxpayers by moving the due date for more deadlines to July 15, 2020. Let’s discuss this additional July 15 Deferral in more detail. July 15 Deferral: Background Information On March 13, 2020, in response to the 2019 coronavirus (also called “COVID-19″) pandemic, President Trump issued […]
On March 31, 2020, the IRS launched the Employee Retention Credit. This new tax credit is designed to encourage businesses to keep employees on their payroll. Let’s discuss the Employee Retention Credit in more detail. Employee Retention Credit: Eligibility Criteria Two categories of employers are not eligible to apply for the Employee Retention Credit: (a) […]
This article explores the third main limitation on the general IRC (Internal Revenue Code) §318 corporate stock re-attribution rules – §318 Sidewise Attribution Limitation. §318 Sidewise Attribution Limitation: What is “Sidewise Attribution”? A sidewise attribution occurs when corporate stock owned by an owner of a business entity (or a beneficiary of a trust or estate) […]