Julia Thomas, Author at Dean Mead

Circular Flow of Funds in Back-to-Back Loan Transactions May Give Rise to Basis under Section 1366(d)(1)(B)

By Julia Thomas | April 17, 2015

At the ABA Tax Section S Corporations meeting held in Houston, Texas, on 1/30/2015, government officials defended their decision not to include in the final Section 1366 and Section 1367 S corporation back-to-back loan regulations an example on loan restructurings involving a circular flow of funds. The statement was made in a panel presentation at…

Check out the latest highlights from Tallahassee @ Dean Mead’s Capitol Report

By Julia Thomas | April 16, 2015

We’re nearing the end of week 7 of the Florida Legislative Session. Focus continues on implementation of Amendment 1 and comprehensive policy revisions to the state’s laws relating to water supply and water quality. The pending legislation dealing with these water issues is summarized below. The budget continues to be complicated by different positions on…

Dean Mead Sponsors Victim Service Center 2nd Annual Cheers to Change Gala

By Julia Thomas | April 10, 2015

Dean Mead is proud to sponsor the Victim Service Center (VSC) 2nd Annual Cheers to Change Gala taking place Friday, April 17th, 2015 at the Mennello Museum of American Art. For more information about this event, click HERE. Victim Service Center of Central Florida is the Certified Rape Crisis Center in Orange and Osceola…

Tax Court Recharacterizes Portion of Bonus Paid to Physician as Nondeductible Dividend

By Julia Thomas | April 7, 2015

In Midwest Eye Center, S.C.,[1] the Tax Court held that $1 million of a $2 million bonus paid to the physician sole shareholder of a personal service corporation was a non-deductible dividend distribution. Under the facts of the case, the taxpayer, a C corporation, conducted an ophthalmology surgery and care center during the tax years at…

Attaching Reason, Not Documents, to Rule 1.130 in The Florida Bar Journal

By Julia Thomas | April 3, 2015

Tim Sobczak, associate in Dean Mead’s Orlando Litigation Department, and Kurt Lee recently co-authored the article titled, “Attaching Reason, Not Documents, to Rule 1.130.” The article, published in The Florida Bar Journal, April, 2015 Volume 89, No.4, may be viewed by clicking the link here: Attaching Reason, Not Documents, to Rule 1.130.

“Transitioning the Family Business” in i4 Business Magazine

By Julia Thomas | April 3, 2015

Matthew Ahearn and Brain Malec, shareholders in Dean Mead’s Estate Planning Department, recently co-authored the article titled, “Transitioning the Family Business: How to Create an Effective Succession Plan.” Their article was published in i4 Business Magazine, April 2015 edition and may be viewed HERE.

Eighth Circuit Denies Like-Kind Exchange Treatment to Taxpayer Attempting to Avoid Related Party Rules of Section 1031(f)

By Julia Thomas | March 30, 2015

In North Central Rental & Leasing, LLC,[1] the Eighth Circuit Court of Appeals determined that the taxpayer, North Central Rental & Leasing, LLC (“North Central”) had improperly claimed non-recognition treatment under Section 1031 with respect to gains from certain property exchanges. Butler Machinery Company (“Butler Machinery”) sold agricultural, mining and construction equipment for manufacturers, primarily…

Tax Court Denies Conservation Easement Deduction Because Property Did Not Constitute a “Qualified Real Property Interest”

By Julia Thomas | March 25, 2015

In Balsam Mountain Investments, LLC,[1] the Tax Court took a very restrictive view of what qualifies as a “qualified real property interest” under Section 170(h)(2)(C), in granting summary judgment in favor of the IRS disallowing a charitable contribution deduction for a conservation easement. In 2003, Balsam Mountain Investments, LLC executed a perpetual conservation easement agreement…

Practice Areas

Estate and Succession Planning

Tax

Agribusiness

Financial Institutions

Posts by Julia Thomas

Circular Flow of Funds in Back-to-Back Loan Transactions May Give Rise to Basis under Section 1366(d)(1)(B)

Check out the latest highlights from Tallahassee @ Dean Mead’s Capitol Report

Dean Mead Sponsors Victim Service Center 2nd Annual Cheers to Change Gala

Tax Court Recharacterizes Portion of Bonus Paid to Physician as Nondeductible Dividend

Attaching Reason, Not Documents, to Rule 1.130 in The Florida Bar Journal

“Transitioning the Family Business” in i4 Business Magazine

Eighth Circuit Denies Like-Kind Exchange Treatment to Taxpayer Attempting to Avoid Related Party Rules of Section 1031(f)

Tax Court Denies Conservation Easement Deduction Because Property Did Not Constitute a “Qualified Real Property Interest”