The “excess loss account” (“ELA”) concept in consolidated tax returns is a huge trap for the unwary. When a consolidated subsidiary corporation becomes worthless, any ELA the parent has in the subsidiary turns into…more

The bankruptcy of Solyndra, Inc. (“Solyndra,” now called 360 Degree Solar Holdings, Inc.) is certainly one of the better-publicized bankruptcies of the last few years. Solyndra is now in the process of…more

Employers are required to collect, account for and pay over certain taxes to the IRS on behalf of their employees. If they fail to do so, not only the employers but also individual “responsible persons” can be personally liable for…more

The recent Tax Court case of Gerdau Mac Steel Inc. et al. v. Commissioner provides some worthwhile real-world insight into the current state of…more

There are many ways to inject extra value into an IRA, most of them involving abusive non-arm’s length transfers. Over the years, the government has not always chosen the most effective means for challenging such transfers. As shown in a recent case, changed tactics improve the…more

This article is guaranteed to contain no health care law content whatsoever. Two recent decisions by important courts have reminded us that tax decisions, while
made prospectively, are often evaluated…more

Normally, selling or exchanging property is a taxable transaction. In the case of an exchange for property of “like kind,” tax on the transaction can be…more

Part of an occasional series on the mechanics and basic structures of important business transactions When a business pays an insurance company for insurance, it immediately deducts the premium. When a business prudently creates a reserve for losses, it receives…more

While imitation is nice, money is actually the sincerest form of flattery. Equity grants can be a convenient way to provide financial benefits to key workers without spending actual cash. Grants of equity in return for the performance of …more

It’s a simple thing to say that two corporations are merging. Actually getting a merger done is a bit more complicated. The mechanics of mergers, and the alternatives for accomplishing them, can have a significant effect on what sorts …more

Like each of us, every business was young once. Also like us, nurturing a business to maturity requires significant resources, energy and skill. This note briefly covers the path many start-up businesses take, highlighting a few pitfalls …more

After an impressive amount of political maneuvering, in December 2011 Congress passed, and the President signed, legislation extending the payroll tax reduction that had been in place during 2011. The extension is for only two months…more

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