August 8, 2016

Should High Net Worth Couples Plan for Divorce Taxes?

For high net worth couples, the division and distribution of marital property are often the most crucial aspect affecting the execution of a divorce or separation […]
July 3, 2015

What Actions of Foreign Persons Affect U.S. Tax Attributes?

In limited circumstances, U.S. tax attributes are affected by the actions of foreign persons with no immediate physical presence in the United States. Consider the following […]
July 28, 2014
What is the Sham Transaction Doctrine?

What is the Sham Transaction Doctrine?

The so-called sham transaction doctrine is “judge made law” which will deny advantageous tax treatment where transactions are carried out primarily for tax avoidance purposes and […]
July 28, 2014
What is the substance over form doctrine

What is the substance over form doctrine

Similar to the sham transaction analysis, the so-called “substance over form doctrine” maintains that the “substance,” rather than the form, of a transaction is what governs […]
July 28, 2014
Does the government regulate tax advisors?

Does the government regulate tax advisors?

Yes—the Treasury Department dictates rules governing practice before the IRS under “Circular 230.” These rules were substantially strengthened and modified after the IRS identified and attacked […]
March 21, 2013

Can State Board of Equalization ignore my business records

Yes, the State Board of Equalization has the authority to essentially ignore the taxpayer’s business records and establish its own conclusions as to the proper sales […]