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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…
Revenue Ruling 99-5 and Section 1031: Bob and Jon’s Excellent Adventure—Part I
Jon was the sole member of Apartment LLC, a disregarded entity for tax purposes. Apartment LLC owned…
Rev. Proc. 2021-20: A Safe Harbor for Missed PPP Deductions
On April 22, 2021, the IRS issued Revenue Procedure 2021-20, which provides a safe harbor allowing taxpayers…