Blogs

Tax Law

Recent Tax Developments

Several major federal tax developments in 2010 affected businesses, estates, and individual taxpayers. In this Bean, Kinney & Korman article published in the BKK Business Law Newsletter, the analysis appears to focus on recent IRS guidance, health care tax changes, and developing rules affecting business planning and estate planning. The article is associated with Bean Kinney tax attorney Ronald A. Feuerstein, although no specific author is listed on the publication itself.

July 1, 2010

Tax Law

Tax Law: Economic Substance Test Enacted as Part of Health Care Law

The Affordable Care Act included several lesser-known tax provisions, including a major change to the federal economic substance doctrine. In this Bean, Kinney & Korman article published in the BKK Business Law Newsletter, the analysis explains that new Internal Revenue Code Section 7701(o) formally codified the economic substance doctrine and required a taxpayer to satisfy both parts of a two-part test. A transaction would only be respected if it meaningfully changed the taxpayer’s economic…

May 1, 2010

Tax Law

Tax Court Finds Gifts of Limited Partnership Interests Don’t Qualify for Annual Gift Tax Exclusion

The Tax Court ruled that gifts of limited partnership interests may not qualify for the annual gift tax exclusion if the recipient does not have an immediate right to use, possess, enjoy, or transfer the gifted interest. In this Bean, Kinney & Korman article published in the BKK Wills, Trusts and Estates Newsletter, Jonathan C. Kinney explains that the court followed its earlier decision in Hackl and found that the Price family’s limited partnership interests were “future interests” rather…

March 1, 2010

tax-court-finds-gifts-of-limited-partnership-interests-dont-qualify-for-annual-gift-tax-exclusion

Tax Law

Tax Law: FIN 48: Will It Be The Feared Road Map for IRS?

FIN 48 expanded the disclosure obligations tied to uncertain tax positions and created concern that businesses would effectively be giving the IRS a roadmap to challenge their tax returns. In this Bean, Kinney & Korman article published in the BKK Business Law Newsletter, the analysis explains that FIN 48 applies to all income tax positions, including decisions not to file returns, allocations among taxing jurisdictions, and classifications of income. The article notes that although FIN 48…

January 1, 2010

tax-law-fin-48-will-it-be-the-feared-road-map-for-irs

Business and Financial Services

Family Limited Partnership and Family Limited Liability Company Valuation Discount Planning

Family limited partnerships and family limited liability companies can provide important estate planning and wealth transfer benefits, but only if they are operated carefully and consistently. In this Bean, Kinney & Korman article published in the BKK Business Law Newsletter, Jonathan C. Kinney explains that the IRS had become increasingly aggressive in challenging valuation discounts used in connection with FLPs and FLCs. The article notes that the IRS often questioned whether a gift was…

January 1, 2009

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Recent Highlights

Blog Post

Blogs

Recent Tax Developments

Tax Law: Economic Substance Test Enacted as Part of Health Care Law

Tax Court Finds Gifts of Limited Partnership Interests Don’t Qualify for Annual Gift Tax Exclusion

Tax Law: FIN 48: Will It Be The Feared Road Map for IRS?

Family Limited Partnership and Family Limited Liability Company Valuation Discount Planning

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