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Federal Tax Law

Corporate Tax Research Papers

Mandatory Passthrough Taxation for Non-Publicly Traded Businesses?

October 30, 2017
A coffee shop in Bintaro, Indonesia by Nafinia Putra via Unsplash

Discussions regarding corporate tax reform often focus on the large, typically public, companies — but what about the treatment of private businesses? In a new research paper, Professor Anthony P. Polito from Suffolk University Law School looks at whether private businesses should receive mandatory passthrough treatment. He ultimately decides that passthrough treatment shouldn’t be mandatory, but comes up with some other ideas for tax reform.…

Federal Tax Law Research Papers

The Treatment of Trees: Like-Kind Exchanges of Timber Rights

September 14, 2017
Timber, logging and forest picture by Photo by Ales Krivec on Unsplash

A new research paper by Brooklyn Law School professor Bradley T. Borden looks at the treatment of like-kind exchanges of timber rights. In general, timber rights do not qualify for Section 1031 recognition,ย which allows for the postponement of tax on property sales if the proceeds are reinvested in similar property as part of a qualifying like-kind exchange.ย …

Federal Income Tax

IRS takes professional golfers to court

September 4, 2017
Golf photo by Lukรกลก Opekar via Unsplash.

Spanish golfer Sergio Garcia recently litigated a $1.7 million tax case arising out of a major endorsement contract with TaylorMade, a golf equipment manufacturer. At issue in the case is how Garcia should characterize the income that he received from the endorsement deal. The income could be classified as personal services, royalties, or a combination of both. (As a Swiss resident, Garcia would only have to pay U.S.…

Case Summaries S Corporations

A Texas landfill goes to Tax Court

August 24, 2017
Landfill photo by Celestine Ngulube via Unsplash.

A Texas couple recently won a novel U.S. Tax Court case involving tax deductions for landfills. The married couple operate a landfill outside of Austin using an S corporation which they co-own with relatives. The IRS disallowed deductions that the couple’s company took for future cleanup costs because the company is a cash-method taxpayer and the IRS contends that the deductions are only available to accrual-method taxpayers. The…

Basics S Corporations

S Corporation basics

August 23, 2017
Man at office building by Chris Davis via Unsplash

Note:ย This is a general information “basics” article. For more information, see FAQ #4. S Corporations Overview An S corporation is a business corporation with a limited number of shareholders whose income is taxed through its shareholders rather than the corporation itself. S corporations are defined in the Internal Revenue Code (26 U.S. Code ยง 1361) which also provides an extensive list of requirements for eligible types of shareholders.…