Posted in Uncategorized on June 8, 2012 | Leave a Comment »
Tax Court validates common S corporation planning idea used to create basis.
Clinton wants tax cuts; Jeb Bush tax increases. What’s next: wearing hats on our feet and hamburgers eating people?
A side-by-side comparison of the tax proposals pitched by Obama and Romney.
Moving pictures explain Rev. Ruling 99-5, Situation 2.
Posted in Uncategorized on June 8, 2012 | 3 Comments »
In this week’s video blog, we complete our virtual tour through Revenue Rulings 99-6 and 99-5, taking on Situation 2 of Revenue Ruling 99-5.
Situation 2 provides an opportunity for a single-member LLC to be converted to a multi-member LLC without the sole member of the SMLLC recognizing any gain. The catch, however, is that the new partner or partners must contribute cash directly to the SMLLC in exchange for partnership interests, and that cash generally cannot be distributed to the sole member for at least two years, lest the transaction run afoul of Section 707 and be recharacterized as a sale by the sole member of a portion of his interest. Ehhh…just watch the video.
