The Step Transaction Doctrine: Page Contents at a Glance Retired high-income earners who have contributed to a Roth IRA may find calculating income taxes confusing, especially […]
With the enactment of IRC Code Section 269, Congress sought to combat certain tax evading strategies involved with the acquisition of a corporation (or its assets). […]
A. Tax Shelters—Generally The Tax Court has consistently disallowed losses, deductions, and credits from transactions it deems to be “tax shelters.” A tax shelter is, among […]
Some people have significant income from more than one source. And some of these people seek to reduce their taxable income by reporting losses from other […]
This is a great question. We consider various alternatives—for example, whether a transaction passes the test under Section 183 but not a related tax doctrine (and […]
Introduction: An Initial Definition The difference between tax evasion and tax avoidance is an important one because “tax evasion” is criminal, but “tax avoidance” is not. […]