In a recent Chief Counsel Advice (“CCA”) issued by the IRS, the IRS concluded that the taxpayer’s sale of stock did not qualify for the gain exclusion as Qualified Small Business Stock (“QSBS”) under Section 1202 since the business of the corporation was akin to brokerage services.[1] The IRS concluded that the corporation’s business, one…
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The IRS Office of Chief Counsel recently issued CCA 202152018 (“CCA”), in which the IRS is attacking yet another business valuation.[1] The IRS takes the position in the CCA that because the valuation used failed to account for a potential acquisition, the grantor retained annuity trust (“GRAT”) failed to properly qualify as a GRAT even…
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Josh Sage discussed the Corporate Transparency Act (“CTA”) in his January 2021 article,[1] and I wrote a follow-up summary last July.[2] The CTA requires certain U.S. businesses, absent an exemption, to file beneficial ownership information with the Financial Crimes Enforcement Network (“FinCEN”). This could result in burdensome reporting obligations for those businesses. As I discussed…
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Since we’re the cool, diamond-handed, trendy-loving, FUD(fear, uncertainty, and doubt)-crushing, FOMO(fear of missing out)-haters and at the same time professionals, now seems just as good of time as ever to discuss what we are doing at our firm to familiarize ourselves and become more competent in the ever-growing and evolving world of magic internet money,…
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In January of 2002 the Internal Revenue Service (“IRS”) issued a press release highlighting a dozen different tax scams and encouraged taxpayers to “maintain national vigilance.”[1] This list was dubbed the “Dirty Dozen,” and the IRS has continued to issue similar press releases containing updated lists of purported tax scams for taxpayers to be on…
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After experiencing an inability to pass as a standalone bill, the Corporate Transparency Act (“Act”) now finds itself tacked to the National Defense Authorization Act for Fiscal Year 2021, being passed by both the House and Senate with veto-proof majorities, 335-78 in the House and 84-14 in the Senate.[1] Following presidential veto, the Senate voted…
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