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In a previous article, I introduced the constructive ownership rules of the Internal Revenue Code (“IRC”) §267. Today, I would like to discuss one of them in more detail – §267 family attribution. §267 Family Attribution: General Rule The §267 family attribution rule is described in §267(c)(2). It states that, for the purposes of determining […]
In a previous article, I introduced the Internal Revenue Code (“IRC”) §267 constructive ownership rules. Today, I would like to focus specifically on the §267 entity-to-member attribution rule. §267 Entity-to-Member Attribution: General Rule §267(c)(1) describes the §267 entity-to-member attribution rule. It states that stocks owned by a corporation, partnership, estate or trust will be treated […]
In a previous article, I discussed the related person definition for the purposes of the Internal Revenue Code (“IRC”) §267. That article, however, focused on the definition itself rather than on a host of supplementary rules necessary to fully understand this definition. In this article, I would like to discuss one set of these rules […]
Internal Revenue Code (“IRC”) §267 imposes significant restrictions on the ability of related persons to recognize loss from a transaction that involves a sale or exchange of property. Hence, it is important for a tax attorney who advises on such a transaction to understand the concept of a “related person” in order to properly advise […]
Sherayzen Law Office wishes everyone a very happy and prosperous New Year 2020! We also wish you stay in full US tax compliance with US international tax laws while your tax burden decreases! And, we are here to help our clients to turn these wishes into reality! In the year 2020, Sherayzen Law Office will […]