In an expected weeklong trial, the family of Carl Pohlad, a billionaire real estate developer and owner of the Minnesota Twins, will argue that the Internal Revenue Service estate tax calculations overstate Pohlad’s remaining interest in the baseball team at his death. The IRS argues the estate owes approximately $255 […]
Category: Tax Controversy
Burger King Worldwide Inc. is in talks to buy Canadian coffee-and-doughnut chain Tim Hortons Inc. in a move that would relocate the hamburger seller’s headquarters to Canada. The two are planning to create a new company. Should the deal be successful, the new entity will be the third-largest quick-service restaurant […]
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 […]
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 […]
On July 17, 2014, the House passed legislation called the “America Gives More Act of 2014” (H.R. 4719). The bill contained “tax extenders” for two charitable tax breaks that could expire, but are normally renewed for one or two years at a time. In addition, there were two new ideas. […]
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 […]
Let’s pick up the thread of a discussion we began earlier this spring about the tax treatment of individual retirement accounts (IRAs). Traditional IRAs and Roth IRAs have historically had significant differences. As we noted in our March 31 post, for example, contributions to a traditional IRA are still tax […]
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 […]
The proper use of retirement accounts is an important part of tax planning for many people. In part, this is because there are some very specific rules that apply to the tax treatment of individual retirement accounts (IRAs). In order to use IRAs effectively to benefit from tax-deferred investments, it […]
A federal judge ruled today that Texas’s ban on same-sex marriage violates the U.S. Constitution. Federal judges in three other states have issued similar rulings in the last three months. In that sense, today’s ruling in Texas could constitute a contribution to a cultural tipping point. For our purposes of […]