Skip to Content

Category: Tax Controversy 

Inversion deals come with capital gains tax headaches

Lately, we have been following the corporate maneuvers designed to reduce U.S. corporate tax burdens. Unlike the recent Kinder Morgan move that will only affect some investors, inversion deals will bring broader unwelcome tax surprises for legacy investors. Medtronic’s acquisition of Covidien provides an example of how an inversion deal […]

Tax Controversy 

Windstream plan to reduce taxes approved by IRS

The Internal Revenue Service recently issued a generally positive private letter ruling regarding Windstream’s plan to spin part of its company into a real estate investment trust. In an unusual move, the company will move its fiber optics and copper networks along with real estate into the REIT and then […]

Tax Controversy 

Hobby loss: tax deductions and human nature

In his influential book “The Wealth of Nations,” published in 1776, the Enlightenment thinker Adam Smith wrote about how human beings like to “truck and barter.” Of course, the “truck and barter” diction seems a bit dated today. But the phenomenon Smith pointed to remains as timely as ever. Humans […]

Tax Controversy 

Choice of entity update: LLCs and S corporations

Tax considerations have long played a role in businesses’ choices of entity. This was true even a generation ago, when the main forms of organization were relatively few: sole proprietorships, partnerships and corporations. It is even more so today, especially with the popularity of relatively new forms of organization: limited […]

Tax Controversy