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Texas Tax Lawyer

Texas%20Tax%20Lawyer%20Fall%202016

Texas Tax

Texas Tax Lawyer A Tax Journal Fall 2016 • Vol. 44 • No. 1 www.texastaxsection.org

  • Page 2 and 3: FROM OUR LEADER: TABLE OF CONTENTS
  • Page 4 and 5: Dear Fellow Tax Section Members: Wi
  • Page 6 and 7: 3. This is Jeopardy Ethics! (What
  • Page 8 and 9: The Battle of the Georges: Exports,
  • Page 10 and 11: failed by a 6 to 5 vote. The absolu
  • Page 12 and 13: since the stamp’s purpose was to
  • Page 14 and 15: policy and the exported goods was c
  • Page 16 and 17: foreign insurers to cover shipment
  • Page 18 and 19: This brief survey of the leading ca
  • Page 20 and 21: [that] is hereby imposed on such cr
  • Page 22 and 23: e paid by the person…exporting th
  • Page 24 and 25: are completely different. Might tha
  • Page 26 and 27: portion of compensation paid from w
  • Page 28 and 29: New Tax Rules Relating to Healthcar
  • Page 30 and 31: Rev. Proc. 2016-44 in order to qual
  • Page 32 and 33: managed property. For example, this
  • Page 34 and 35: IRS LAUNCHES RENEWED ATTACK ON VALU
  • Page 36 and 37: IRS LAUNCHES RENEWED ATTACK ON VALU
  • Page 38 and 39: IRS LAUNCHES RENEWED ATTACK ON VALU
  • Page 40 and 41: IRS LAUNCHES RENEWED ATTACK ON VALU
  • Page 42 and 43: However, the partnerships that woul
  • Page 44 and 45: on partnership taxable years beginn
  • Page 46 and 47: In 2007, the IRS issued Revenue Rul
  • Page 48 and 49: the extent they are funded as of th
  • Page 50 and 51: guide them in their partial plan te
  • Page 52 and 53:

    policies each owned, specifically w

  • Page 54 and 55:

    The Statute of Limitations for Asse

  • Page 56 and 57:

    When an original tax return was fil

  • Page 58 and 59:

    for the filing” of a tax return w

  • Page 60 and 61:

    INDEX I. LIMITS ON FAVORABLE CAPITA

  • Page 62 and 63:

    INDEX G. Administrative Considerati

  • Page 64 and 65:

    INDEX H. Pass-Through Entities ....

  • Page 66 and 67:

    (2) Assets. Generally, any asset ca

  • Page 68 and 69:

    Accounts Payable 100,000 Total 300,

  • Page 70 and 71:

    Gain 795,000 Federal income tax at

  • Page 72 and 73:

    1. Generally, a lease is a contract

  • Page 74 and 75:

    (4) In general, no part of the cost

  • Page 76 and 77:

    Since Texas is in the Fifth Circuit

  • Page 78 and 79:

    2. Planning for Offsetting Built-In

  • Page 80 and 81:

    (9) That the transfer of money or o

  • Page 82 and 83:

    A. Basis Step-Up (or Step-Down) On

  • Page 84 and 85:

    3. Qualified Conservation Easements

  • Page 86 and 87:

    partnership must have a valid Code

  • Page 88 and 89:

    B. Gain on Partnership Distribution

  • Page 90 and 91:

    eallocated from Property B to Prope

  • Page 92 and 93:

    VII. OFFSETTING GAIN: YOU CAN’T P

  • Page 94 and 95:

    1. Recourse Debt. In the second pat

  • Page 96 and 97:

    “Capital Gain Bar Rule”). 110 U

  • Page 98 and 99:

    transaction is characterized for st

  • Page 100 and 101:

    lease. Such income is subject to de

  • Page 102 and 103:

    5. Note: Many parties consider empl

  • Page 104 and 105:

    • The one-year holding period for

  • Page 106 and 107:

    inventory item and the balance of t

  • Page 108 and 109:

    assets test, all members of the par

  • Page 110 and 111:

    deductible expense. “Qualifying p

  • Page 112 and 113:

    eliably estimated. In some cases, t

  • Page 114 and 115:

    productive use in a trade or busine

  • Page 116 and 117:

    sales; 4. the extent of the subdivi

  • Page 118 and 119:

    a situation has achieved nothing wi

  • Page 120 and 121:

    Overview * For C corporations, ther

  • Page 122 and 123:

    Beware S Corporations With Built-In

  • Page 124 and 125:

    Beware S Corporations With Built-In

  • Page 126 and 127:

    Determining Built-In Gains * The am

  • Page 128 and 129:

    Avoiding The Built-In-Gain Tax * Wa

  • Page 130 and 131:

    Avoiding The Built-In-Gain Tax * Li

  • Page 132 and 133:

    Avoiding The Built-In-Gain Tax * IR

  • Page 134 and 135:

    Avoiding The Built-In-Gain Tax * In

  • Page 136 and 137:

    Avoiding The Built-In-Gain Tax * Le

  • Page 138 and 139:

    Postmortem Basis Step-Up * Decedent

  • Page 140 and 141:

    Postmortem Basis Step-Up Exceptions

  • Page 142 and 143:

    Postmortem Basis Step-Up Exceptions

  • Page 144 and 145:

    Planning for Basis Step-Up * Consid

  • Page 146 and 147:

    Planning for Basis Step-Up * Partne

  • Page 148 and 149:

    New Basis Consistency Requirements

  • Page 150 and 151:

    New Basis Consistency Requirements

  • Page 152 and 153:

    New Basis Consistency Requirements

  • Page 154 and 155:

    Change Asset Basis without Gain or

  • Page 156 and 157:

    Change Asset Basis without Gain or

  • Page 158 and 159:

    Change Asset Basis without Gain or

  • Page 160 and 161:

    Change Asset Basis without Gain or

  • Page 162 and 163:

    Using PALs to Offset Gain * What qu

  • Page 164 and 165:

    Using PALs to Offset Gain * What do

  • Page 166 and 167:

    Restructuring Debt: Ordinary Income

  • Page 168 and 169:

    Related Party Sale of Depreciable P

  • Page 170 and 171:

    Related Party Sale of Depreciable P

  • Page 172 and 173:

    Sale of Mineral Interests: Royalty

  • Page 174 and 175:

    Sale of Patents * Patent Exception

  • Page 176 and 177:

    §751 Hot Assets * A selling partne

  • Page 178 and 179:

    §1202 * For its stock to be qualif

  • Page 180 and 181:

    §1202 * For substantially all of t

  • Page 182 and 183:

    §1202 * Per issuer Limit. Excluded

  • Page 184 and 185:

    Depreciation - Basis Allocation * O

  • Page 186 and 187:

    Depreciation - Basis Allocation * P

  • Page 188 and 189:

    Depreciation Recapture * Recapture

  • Page 190 and 191:

    5 th Circuit Factors to Determine

  • Page 192:

    2727 Allen Parkway Suite 1700 Houst

  • Page 206 and 207:

    17 2016 Tax Section Annual Meeting

  • Page 208 and 209:

    25 SBOT Tax Section Officer Monthly

  • Page 210 and 211:

    Feb. 2017 3 Tax Law in a Day CLE Lo

  • Page 212 and 213:

    23 2017 Tax Section Annual Meeting

  • Page 214 and 215:

    Appointed Council Members Jason B.

  • Page 216 and 217:

    Ex Officio Council Members Alyson O

  • Page 218 and 219:

    COMMITTEE CHAIR VICE CHAIR 4. Emplo

  • Page 220 and 221:

    COMMITTEE CHAIR VICE CHAIR 9. Partn

  • Page 222 and 223:

    COMMITTEE CHAIR VICE CHAIR 14. Tax-

  • Page 224:

    COMMITTEE CHAIR VICE CHAIR 20. Lead

Michael Thomas, Barrister, Grays Inn Tax Chambers. mt@taxbar ...
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