Insights

Sometimes it’s what you say, not what you do, that matters. A taxpayer learned that the hard way in a recent United States Tax Court decision. There are numerous court decisions in which a taxpayer acquired property, incurred “soft costs” to entitle the property for future development, and then recognized capital gain…

Estate Planning is hard for many reasons—from discomfort with death to difficult family dynamics. It is made harder by complicated tax laws and documents. Too often, in estate planning, the focus is solely on tax planning without considering the impact of the planning upon the family or incentivizing the type of…

The Internal Revenue Code prescribes minimum imputed interest rates and time-value-of-money factors applicable to certain loan transactions and estate planning techniques. These rates are tied formulaically to market interest rates. The Internal Revenue Service updates these rates monthly. These are commonly applicable rates in effect for June 2015: Short Term AFR…

Protecting your company’s trademarks is important to grow your brand and prevent other companies from trading off your hard-earned goodwill. Below are a few things to keep in mind when creating and protecting trademarks: Choosing a Trademark There are a number considerations when choosing your company’s trademark. Among other things, you…

In CNT Investors, LLC v. Commissioner, 114 T.C. No. 11 (2015), the Tax Court recently held that a retired mortician reasonably relied on the advice of his long-time corporate and estate planning attorney in participating in a Son-of-BOSS tax shelter transaction to divest real estate holdings. Although the court ruled that…