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Archive for the ‘Federal Taxation’ Category

Florida DOR Seeks Input for TCJA Impact Analysis

Published: August 9th, 2018

By: H. French Brown, IV Robert S. Goldman Mark E. Holcomb

The Florida Department of Revenue is currently examining the impact of the 2017 federal Tax Cuts and Jobs Act on Florida’s corporate income tax system. As part of that process, the Department is soliciting input from taxpayers regarding the effects of the TCJA. The Department’s evaluation will likely identify options for changing the Florida Corporate […]

Chambers USA 2018 Recognizes Seven Dean Mead Attorneys for Legal Excellence

Orlando, Fla. – Dean Mead has been ranked among the top Florida law firms in Chambers USA 2018 America’s Leading Lawyers for Business, an annual publication by Chambers and Partners. The rankings include seven of the firm’s attorneys in the categories of Tax and State and Local Taxation. The attorneys receiving the prestigious recognition include: […]

Legislative Update: The Federal Tax Cuts and Jobs Act and the Risk for Florida Corporate Taxpayers

Published: February 16th, 2018

By: H. French Brown, IV

This is an update to our previous article, Eyes on the Legislature: The Federal Tax Cuts and Jobs Act and the Risk for Florida Corporate Taxpayers written by Michael B. Dobson & Robert S. Goldman.  That article provided a general overview of how Florida’s corporate income tax “piggybacks” the Internal Revenue Code, and how the Florida […]

Stock Surrender and Repurchase Lacks Economic Substance

Published: September 27th, 2017

By: Stephen R. Looney

It has long been a basic tenet of federal tax law that, in order to be respected for tax purposes, a transaction must have economic substance.  In a recent decision, the Tax Court once again held that a purported sale or exchange lacking in economic substance will not be respected.  The case also demonstrates that […]

Tax Court Holds Income was Improperly Attributed to S Corporation

Published: March 28th, 2017

By: Stephen R. Looney

In a recent case, the Tax Court addressed the issue of whether income should be reported by a Taxpayer providing services or an S corporation established by the Taxpayer. Taxpayers often seek to report income generated from services provided through an S corporation on such S corporation’s tax return, but as the case below demonstrates, […]

Widow Allowed to Expense Previously Expensed Farming Inputs

Published: January 17th, 2017

By: Brad Gould

In the case of Estate of Backemeyer v. Commissioner, 147 TC 17 (2016), the Tax Court held that the widow of a Nebraska farmer was entitled to expense farming inputs she inherited from her husband, who had expensed the same inputs during his life. Mr. Backemeyer, a corn and soybean farmer, purchased farming inputs consisting of seed, […]

Long-Awaited Proposed Regulations for Section 2704 Issued!

Published: August 2nd, 2016

By: Dana M. Apfelbaum

Section 2704 of the Internal Revenue Code provides for special rules relating to the valuation of transfers of business interests to certain family members for estate, gift, and generation-skipping transfer tax purposes (collectively the “transfer taxes”).  Practically, § 2704 limits the ability to lower the value of a business interest as determined for transfer tax […]

Compensation to Law Firm Shareholder-Employees Disallowed by Tax Court

Published: March 17th, 2016

By: Stephen R. Looney

In Brinks,[1] the Tax Court once again applied the independent investor test to recharacterize compensation paid by a professional corporation, a law firm, to its shareholder-employees as nondeductible dividend distributions, and held the corporation liable for accuracy-related penalties for mischaracterizing the dividends as deductible compensation. This case should serve as a warning for many mid-size […]