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Insights Business & Tax Blog

Join Us: Doing Business in China Executive Briefing

September 7, 2016 International Business

We invite you to join us for an engaging, informative presentation on doing business in China. Williams Parker is pleased to host Maarten Roos and Robin Tabbers, lead partners of R&P China Lawyers (Shanghai) and authors of articles recently published in Requisite V – The International Edition. Our guests will provide practical guidance…

2704 Regulations Explained: Why is the IRS Targeting Valuation Discounts on Family Controlled Entities?

September 6, 2016 2704 Regulations

The simple answer is that the IRS believes that valuation discounts taken on family-controlled entities are falsely high, which results in lower transfer tax revenue to the Treasury. With the foregoing in mind, it is important to understand how the IRS, courts, and taxpayers value a business interest under current…

Applicable Federal Rates for September 2016

August 23, 2016 Applicable Federal Rates

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 September 2016: Short Term AFR…

Want to Diversify an Appreciated Asset Position Without Paying Capital Gains Tax? Take a Federal Government Job With a Conflict of Interest.

August 17, 2016 Capital Gain Transactions

If you want to convert a substantially appreciated asset into a diversified asset portfolio without paying capital gains tax, choose your favorite Presidential candidate with extra care. He or she could save you a lot of tax by giving you a job. If that candidate becomes President, appoints you to…

Tax Court Approves Non-Safe-Harbor “Reverse” 1031 Exchange Even Though Titleholder Had No Ownership Benefits or Burdens

August 12, 2016 1031 Exchange

A 1031 Exchange is a popular capital gains deferral strategy for business and investment property. Taxpayers use the strategy to defer capital gains tax on property “sold” by acquiring “like-kind” replacement property, usually in coordination with an intermediary or accommodation party. After deliberating for a decade, the U.S. Tax Court…