Tax Benefits of Charitable Remainder Trusts

Charitable giving is often an important part of an individual’s tax and estate planning strategy. One popular vehicle for charitable giving is a Charitable Remainder Trust (“CRT”), which can provide significant tax benefits for the donor and a stream of income for non-charitable beneficiaries during their lifetime. CRTs are valid, they can have some tax……

Explaining Real Estate Profesional Status to IRS Employees

In the complex realm of the legal system, judges hold the vital responsibility of making impartial decisions, drawing from their wealth of life experiences. These experiences, in turn, have a profound influence on the judgments they render. This principle extends to other government officials as well, such as IRS agents, auditors, and attorneys, who are……

An Appraisal is Not Always Needed for a Casualty Loss Deduction

Casualty losses are often challenged by the IRS, as they meet the “large, unusual, or questionable” (“LUQ”) standard for pulling returns for audit. On audit, the IRS insists on an appraisal from a third party that shows the difference in fair market value before and after the casualty event. Even if an appraisal is provided……

Tax Implications of Debt vs. Equity in Related Entities

Investors who engage in successful ventures often also invest in less successful ones. In some cases, one venture ends up funding another. When a taxpayer operates through multiple legal entities, this can lead to numerous complexities. For example, “due to” and “due from” intercompany transactions raise questions, even if they do not involve international transfers.……

If a Foreign Entity is a Foreign Trust

United States persons who have foreign transactions present a number of compliance problems for the IRS. It is difficult for the IRS to know whether taxpayers are simply not paying U.S. taxes on foreign transactions. The IRS officially recognized the significance of its international tax limitations in 2010 when it renamed its large business division……

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