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When Worlds Collide: How Tangible Tax Burdens Attach to Digital Commerce across the Globe (Part 1)
The world is at a crossroads. The early 1990’s saw the internet opening to the general public, followed shortly thereafter by online sales platforms (Book Stacks Unlimited—1992, Amazon.com—1994, and eBay—1995), and social media platforms in the 2000’...
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Today in Tax: Spin-offs, Tax Elections, and Subpart F
Taxpayers Not Allowed to Revoke Tax Elections Based on Later Change in Regulation
Regulations frequently change as Congress adopts new policies and the IRS issues new or revised regulations implementing those policy changes. Tax elections based on e...
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Burr Takes Aim . . . This Time at Non-Taxable Scholarships
On September 29, 2021 Senator Richard Burr (R-NC) introduced legislation that would cause student-athletes to pay federal income tax on athletic scholarships if those student-athletes earn more than $20,000 in receipts from monetizing their name, ima...
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Charitable Remainder Trusts: An Option to Consider
Those wishing to sell and diversify highly appreciated assets (stocks, real estate) and those who have lots of taxable income should consider a charitable remainder trust (“CRT”) to minimize income tax on capital gains as well as gift and estate tax....
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Tips for Nonprofit Subsidiary LLCs
Nonprofit charities regularly own or receive donations of real estate. In the real estate world, holding title to property in an isolated limited liability company is so common that many lenders’ and brokers’ template forms refer to “______ LLC,” wit...
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Goodwill Can Be Exchanged if Treated as Real Estate
When attempting to exchange a business, exchanging the goodwill component is often a dead end. Goodwill of two different businesses may never be of like kind. Treas Reg § 1.1031(a)-2(c)(2). Goodwill associated with real estate, however, can generally...
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