By Jonathan Prokup & Dustin Covello Four years have passed since Congress enacted the Troubled Assets Relief Program, better known as TARP. After Treasury determined that frozen credit markets were threatening the U.S. financial industry and even the entire economy, it asked Congress to authorize the purchase of illiquid mortgages from banks. Congress obliged, authorizing [...]
Archive for the ‘Corporate’ category
The IRS Can Summons California For Property Transfer Records
December 20, 2011As noted by Janet Novack at forbes.com, Judge England of the District Court for the Eastern District of California last week issued an order permitting the IRS to serve a “John Doe” summons on the California State Board of Equalization. The summons seeks the names of residents who transferred property to relatives for little or [...]
Southgate Master Fund: The Sham Partnership Doctrine Gets Messy… Or Does It?
December 13, 2011By Jonathan Prokup Two weeks ago, the Fifth Circuit summarily rejected a taxpayer request for an en banc rehearing in Southgate Master Fund LLC v. United States. The appellate court had previously concluded that the taxpayer was not entitled to a claimed capital loss from a transaction involving the acquisition of distressed debt via a [...]
Musings in the Aftermath of the First Schedule UTP Filing Season
December 8, 2011By Phil Karter As reported earlier this week in the tax press, the recently completed initial filing season for Schedule UTP produced at least one major surprise in the eyes of IRS officials, who had anticipated a much greater number of items listed on the average Schedule UTP than actually materialized. In fact, the IRS’s [...]
Small Businesses, Schedule UTP, and High-Wealth Audits
December 7, 2011By Jonathan Prokup Peter Pappas at the Tax Lawyer’s Blog takes note of a recent report from TIGTA regarding audits of small corporations (those with less than $10 million in assets, according to the IRS). As Mr. Pappas says, language from the report suggests that Treasury may consider the closely held nature of many small [...]
Tax Foundation: Rethinking U.S. Taxation of Overseas Operations
December 1, 2011By Jonathan Prokup Our in-house and private-practice corporate readers will likely enjoy one of the Tax Foundation’s newest reports: Rethinking U.S. Taxation of Overseas Operations. As the abstract describes: The United States produces a third of the world’s wealth but contains less than 5 percent of the world’s population. This disparity pushes many U.S. businesses [...]
Businesses Prepare For The End Of The Euro; Will Treasury Do The Same?
November 29, 2011By Jonathan Prokup According to the Financial Times, companies around the world are preparing for the possibility of a breakup of the euro. Given the currency devaluation that would likely occur in countries coming out of the euro, these companies are preparing for the impact that such an event would have on balance sheets (e.g., [...]
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Phil Karter
Jonathan Prokup
David Shakow
George Connelly, Jr.
Buck Buchanan
David Bernard
Dustin Covello
Heather Pesikoff
Hale Sheppard
