News Updates

We Stay Up-To-Date on Flow-Through Tax News and Precedents So You Don't Have To.

Below you will find recent rulings and updates affecting flow-through taxes and closely-held business structures. If you have any questons on these, or about any updates on other sites, please do not hesitate to reach out to us for further insights.

If you see anything you believe is important to your flow-through peers and collaborators that is not covered below, please share that with us as well. We'd appreciate it.

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Incorporation of a Partnership

While flow-through taxation still is generally the way to go for the closely held business, it is not uncommon for a partnership to incorporate with a view of engaging in an exit transaction after five years via a stock sale that qualifies for the 100% exclusion of gain provided by §1202. Here is a nuance of this Code that came up in our practice.

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Favorable §1202 Ruling: A Follow-up

A follow-up regarding PLR 202114002 (the favorable §1202 ruling involving an insurance agent/broker), courtesy of Eide Bailly.

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Favorable §1202 Ruling

PLR 202114002 is a taxpayer-liberal PLR, which provides that a business referred to as an “insurance agent or broker” was a qualified trade or business for §1202 purposes.

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PPP tax-exempt income and AAA

How is an S corporation’s accumulated adjustment account (“AAA”) impacted by forgiven PPP loan proceeds? The answer is not as easy as it first may seem.

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Unfavorable Discounting of Split Charitable Bequest

Chuck and Michael opine on Warne v. Commissioner, TC Memo 2021-17, a case that addressed, among other issues, an estate tax charitable deduction.

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New 2020 At-risk Rule Reporting Requirements

Learn about the tax basis capital account reporting requirements.

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None of the authors is rendering legal, accounting or other professional advice. If such advice is required, it is strongly recommended that a professional advisor be engaged.

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