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The Coming FinCEN Reporting Requirements
On December 7, 2021, Treasury’s Financial Crimes Enforcement Network (FinCEN) issued a Notice of Proposed Rulemaking which promulgated proposed…
The Pass-Through Entity Tax (AB 150) and SB 113 Amendments
Introduction In July 2021, California passed Assembly Bill 150, which contained the Small Business Relief Act, adding…
The IRS Wishes LIBOR a Fond Farewell with Final Regulations
Introduction LIBOR (London Interbank Offered Rate) has been universally used as a reference interest rate for contracts…
Divide and Conquer—A Primer on Partnership Divisions
Partnership divisions under IRC Section 708(b)(2)(B) can be useful in several contexts. Partnership divisions are also quirky,…
Appellate Court Finds Federal Conservation Easement Regulation Invalid
The Eleventh Circuit Court of Appeals recently invalidated a technical provision in the Treasury Regulations controlling conservation…
California Registration and Taxation of Foreign Entities
Introduction. When must a foreign entity (i.e., a corporation, LLC, or limited partnership formed under the laws…
Claiming the Employee Retention Credit for Past Quarters Using Form 941-X
The Employee Retention Credit (ERC) is a tax credit available to employers who have seen a reduction…
IRS Excludes Cryptocurrency Exchanges From Section 1031
Cryptocurrency is cool these days. And since this Tax Blog aspires to be cool (with mixed results),…
Revenue Ruling 99-6 and Section 1031: Bob and Jon’s Excellent Adventure—Part II
Bob and Jon were the members of Apartment LLC, an LLC taxed as a partnership, with Bob…