Partnerships - Llc

Bob Keebler talks about the issue of "carried interest" and the Bill working its way through the House and Senate. This Podcast is sponsored by Leimberg Information Services, Inc. at http://www.leimbergservices.com Please visit our software, books, and PowerPoint Presentations site at http://www.leimberg.com

This is Part IIA of Wilmington Trust's "2010 Future Vision of Estate Planning - Issues You Probably Never Considered - But Should Now." Dick Nenno and his panel of Carol Cantrell, M. Read Moore, and Jeff Pennell provide a frank, fascinating, provacative, and informative picture of where we are now - and where we should be going in estate planning. Be sure to listen to Part III. This Podcast is sponsored by Leimberg Information Services, Inc. at http://www.leimbergservices.com Please visit our software, books, and PowerPoint Presentations site at http://www.leimberg.com

This is Part III of Wilmington Trust's "2010 Future Vision of Estate Planning - Issues You Probably Never Considered - But Should Now." Dick Nenno and his panel of Carol Cantrell, M. Read Moore, and Jeff Pennell provide a frank, fascinating, provacative, and informative picture of where we are now - and where we should be going in estate planning. Our thanks to Dick Nenno, Carol Cantrell, Read Moore, and Jeff Pennell for a terrific view of where we are now and what's coming up. This Podcast is sponsored by Leimberg Information Services, Inc. at http://www.leimbergservices.com Please visit our software, books, and PowerPoint Presentations site at http://www.leimberg.com

This is Part II of Wilmington Trust's "2010 Future Vision of Estate Planning - Issues You Probably Never Considered - But Should Now." Dick Nenno and his panel of Carol Cantrell, M. Read Moore, and Jeff Pennell provide a frank, fascinating, provacative, and informative picture of where we are now - and where we should be going in estate planning. Be sure to listen to Part III. This Podcast is sponsored by Leimberg Information Services, Inc. at http://www.leimbergservices.com Please visit our software, books, and PowerPoint Presentations site at http://www.leimberg.com

Dick Nenno of Wilmingtion Trust returns to provide a "2010 Future Vision of Estate Planning - Issues You Probably Never Considered - But Should Now." Dick and his panel of Carol Cantrell, M. Read Moore, and Jeff Pennell provide a frank, fascinating, provacative, and informative picture of where we are now - and where we should be going in estate planning. Be sure to listen to Parts II and III. This Podcast is sponsored by Leimberg Information Services, Inc. at http://www.leimbergservices.com Please visit our software, books, and PowerPoint Presentations site at http://www.leimberg.com

This PodCast is about Net Operating Losses. The IRS has issued a revised ruling on the use of a net operating loss under the new rules Congress added in February. The new ruling, Revenue Ruling 2009-26, updates and liberalizes the guidance previously given in Revenue Ruling 2009-19 issued on March 16. The new guidance allows taxpayers to simply file a carryback for the appropriate number of years to make the election, but there are special due date rules you have to worry about. The materials are at http://www.edzollars.com/2009-05-04_NetOperatingLoss.pdf. This Podcast is sponsored by Leimberg Information Services, Inc. at http://www.leimbergservices.com Please visit our software, books, and PowerPoint Presentations site at http://www.leimberg.com

This PodCast concerns a case dealing with the trust fund recovery penalty under "6672. In the case of Richard A. Smith v. United States, 2009 TNT 30-6, CA10, (http://ca10.washburnlaw.edu/cases/2009/02/07-4210.pdf) the Tenth Circuit refused to overturn the holding in the US District Court of Utah that Mr. Smith was a responsible person, even though he had no ownership interest in the entity in question. The case highlights the dangers for employees in accounting functions when the organization they work for begins to have cash flow problems, and payroll tax payments begin to be skipped.The materials are available at http://www.edzollars.com/2009-02-23_Responsible.pdf . This Podcast is sponsored by Leimberg Information Services, Inc. at http://www.leimbergservices.com Please visit our software, books, and PowerPoint Presentations site at http://www.leimberg.com

This PodCast is about the American Recovery Reinvestment Act of 2009. It has a number of tax provisions, and this podcast looks at the small business net operating loss provisions of the Act. This provision will require action for some taxpayers within 60 days after the bill is signed into law, as well as giving us a "sliding" window for when we start using a net operating loss for the year we elect to have it apply to. The podcast materials are located at http://www.edzollars.com/2009-02-16_NOL.pdf . This Podcast is sponsored by Leimberg Information Services, Inc. at http://www.leimbergservices.com Please visit our software, books, and PowerPoint Presentations site at http://www.leimberg.com

This PodCast pertains to a common accounting issue, the differences between tax and GAAP treatment of items. Here, we focus on a case involving the time for recognizing an expense. The matter involved rebates and we look at a Chief Counsel Memorandum (ILM 200834019) outlining the IRS's view on why the taxpayer in this case could not recognize the expense related to rebates at the time a sale was made. Materials for this week's podcast can be downloaded at http://www.edzollars.com/2008-09-01_Rebates.pdf This Podcast is sponsored by Leimberg Information Services, Inc. at http://www.leimbergservices.com Please visit our software, books, and PowerPoint Presentations site at http://www.leimberg.com

This podcast is the sequel to a November 2006 podcast on the same case--that of Kadillak v. Commissioner where an individual who was caught by the "dot bomb" crash of the technology stock of his former employer attempted to mitigate the damage caused by his ISO exercise and 83(b) election made at the height of the craze. A year later, Mr. Kadillak was no longer employed by the organization, the stock price had tanked, and when he sold the stock that he didn't have to surrender got stuck with a $3,000 per year AMT capital loss deduction (probably for lifetime) to "offset" a large prior year AMT liability. The Ninth Circuit has now ruled on the case and, unfortunately for Mr. Kadillak, agreed with the Tax Court's decision. We look at the Section 83(b) election, it's downside risk that Mr. Kadillak obtained "up close and personal" experience with, and some general observations on counseling clients about the "what if" problem when they are sure they know what the future will hold. The materials are available a

This PodCast is about the preparer standards and tax return positions. In the case of Wadsworth v. Commissioner, TC Memo 2008-171, we see a real world situation where a tax professional decided a position was not one that he could accept and what happened when the client decided to find another person who would take the requested position. As you might expect, the taxpayers don't fare well in the eyes of the court when they attempt to claim reliance on the advice of the professional that did sign off on the position. The materials for this week are available at http://www.edzollars.com/2008-07-28_Preparer_Shop.pdf . This Podcast is sponsored by Leimberg Information Services, Inc. at http://www.leimbergservices.com Please visit our software, books, and PowerPoint Presentations site at http://www.leimberg.com

This Podcast is about temporary regulations that deal with start-up and corporate and partnership organization costs. Interestingly enough, the new regulations now create an automatic election to expense/amortize all such costs, and treat problems related to the identification of costs or the proper year to begin amortization as accounting method issues. The materials are located online at http://www.edzollars.com/2008-07-14_Section_195.pdf . This Podcast is sponsored by Leimberg Information Services, Inc. at http://www.leimbergservices.com Please visit our software, books, and PowerPoint Presentations site at http://www.leimberg.com

This Podcast pertains to HSA Accounts. The IRS has issued guidance in the form of a series of questions and answers related to Health Savings Account in Notice 2008-59. This podcast covers some of the planning and design opportunities available under this Notice. Written materials for this podcast can be downloaded from http://www.edzollars.com/2008-06-30_HSA_Guidance.pdf . This Podcast is sponsored by Leimberg Information Services, Inc. at http://www.leimbergservices.com Please visit our software, books, and PowerPoint Presentations site at http://www.leimberg.com

This PodCast is part two of a series on the proposed regulations for preparer penalties. . The materials are at http://edzollars.com/2008-06-23_Penalty.pdf . This Podcast is sponsored by Leimberg Information Services, Inc. at http://www.leimbergservices.com Please visit our software, books, and PowerPoint Presentations site at http://www.leimberg.com

This PodCast is the first of what will be a series of two on the proposed regulations for preparer penalties. Considering the length of the regulations and podcast, the first hour is in this file to listen to and digest, with part two to be posted later. The materials are at http://edzollars.com/2008-06-23_Penalty.pdf . . This Podcast is sponsored by Leimberg Information Services, Inc. at http://www.leimbergservices.com Please visit our software, books, and PowerPoint Presentations site at http://www.leimberg.com

This PodCast reviews the step transaction doctrine and where the line is drawn when we deal with the application of the step transaction doctrine in the formation of a family limited partnership. The IRS attempted to use their victory in the Senda case to get the same result in Holman v. Commissioner, 130 TC No. 12. But in an opinion that reminds us of the importance of the facts of the specific case in question, the Tax Court refused to take that step. Materials for this week's podcast can be downloaded from http://edzollars.com/2008_06_09_Holman.pdf. Be sure to also look at the commentary of Owen Fiore, Paul Hood, and Jeff Pennell in our LISI Estate Planning archives. This Podcast is sponsored by Leimberg Information Services, Inc. at http://www.leimbergservices.com Please visit our software, books, and PowerPoint Presentations site at http://www.leimberg.com

This PodCast deals with a Fifth Circuit ruling in Kornman & Associates, Inc. v. United States on whether a taxpayer who set up a Son of BOSS style shelter would get the benefit that was expected--and the taxpayer was disappointed. The case offers a chance to review the unusual impact that liabilities have in a partnership context, as well as the question of just what is a liability for this purpose. The materials for this podcast can be downloaded at http://www.edzollars.com/2008-05-19_Partnership_Liabilities.pdf . This Podcast is sponsored by Leimberg Information Services, Inc. at http://www.leimbergservices.com Please visit our software, books, and PowerPoint Presentations site at http://www.leimberg.com

This PodCast is about the interplay between partnership taxation and tax shelters taken beyond the spirit of the law. Partnership taxation is one of those areas where things may not work exactly as many practitioners expect, and those unexpected workings are things that tax shelter promoters have attempted to make use of. But if you are going to try and use the technical details of the tax law to force the IRS to grant you a tax benefit that otherwise doesn't seem like something that should happen, it's helpful to follow the detailed requirements yourself. Unfortunately for the taxpayer in 7050 Ltd. v. Commissioner, TC Memo 2008-12, that didn't quite happen--and while one bullet was dodged, another problem proved fatal to the benefit the taxpayer was after, and the court never had to deal with whether the shelter actually would have worked if executed as it was supposed to have been. The materials are available at http://www.ezollars.com/2008-05-05_Sloppy.pdf . This Podcast is sponsored by Leimberg Inf

This PodCast follows the continuing saga of the self-employment tax and qualified joint venture. It analyzes CCA 200816030 issued by the IRS that outlines the "new improved" IRS position on self-employment tax and the Qualified Joint Venture election under "761(f).The materials for the podcast are available at http://www.edzollars.com/2008-04-28_SEandQJV.pdf . . This Podcast is sponsored by Leimberg Information Services, Inc. at http://www.leimbergservices.com Please visit our software, books, and PowerPoint Presentations site at http://www.leimberg.com