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Business
Investing

Corporate Tax Planning

Updated 9 days ago

Business
Investing
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Covers C (regular) corporate taxation and planning including taxation of shareholders

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Covers C (regular) corporate taxation and planning including taxation of shareholders

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Cover image of Corporate Tax Planning

Corporate Tax Planning

Updated 9 days ago

Read more

Covers C (regular) corporate taxation and planning including taxation of shareholders

Rank #1: How Much to Tell--Adequate Disclosure and Section 6501(e) - Ed Zollars

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This PodCast uses the case of Benson v. Commissioner, TC Memorandum 2006-55, to examine the issue of what constitutes adequate disclosure under Section 6501(e)(1)(A)(ii) for purposes of avoiding the otherwise mechanical application of an extended six year statute on substantial underpayments. 

In this case, which the taxpayer ends up losing, the Court considers to what extent disclosures on other returns can "make up" for items not disclosed directly on the individual return.

The text file for this podcast can be downloaded from http://www.edzollars.com/2006-04-08_Adequate_Disclosure.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

Apr 07 2006

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Rank #2: Whose Debt Is It Anyway? S Corporations and Loans from Related Entities - Ed Zollars

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This Podcast is about loans, S Corporations, and reality engineering. Shareholder debt to S corporations has proven to be a minefield for shareholders and their advisers, and the taxpayer and their adviser in the case of Ruckriegel v. Commissioner managed to step on a shareholder debt/basis mine twice in two consecutive IRS exams.  In this case, the shareholders attempted to argue that loans from a partnership they controlled were actually loans to them from the partnership, followed by loans to the corporation.

Or, to put it more correctly, their CPA attempted to argue that.  One of the problems in this case, beyond the simple fact that the form of the transaction (which the taxpayers had control over) did not agree with what they were arguing was the true substance, was the fact that neither the taxpayers nor their inside accountant were treating these loans as if they had traveled that indirect route.  The case points up the dangers of attempting to "after the fact" correct client missteps--and especially continuing to do it for multiple years.

The materials for this podcast are found at http://edzollars.com/2006-04-29_Debt.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

Apr 28 2006

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Rank #3: I'm a Yankee Doodle Dandy-Just Not a Good Recordkeeper..- Ed Zollars

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This Podcast focuses on the issues and limitations involving the Cohan rule and its use in tax compliance and representation work.

The materials can be downloaded from http://edzollars.com/2006-03-25_Cohan.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

Mar 24 2006

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Rank #4: In God We Trust, All Others Must Deposit With Us-Payroll Tax Trust Funds - Ed Zollars

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This PodCast covers issues involving payroll tax deposits, including the IRS and Social Security Administration recent caution about the use of payroll services to deposit taxes.

This week we look at a case that invovled the embezzlement of payroll tax deposits by a payroll service, where the IRS successfully argued that the employer still was liable for the unpaid taxes even though they had believed the payroll service had deposited the taxes

As well, we look at a case involving a shareholder who stumbled into a full trust fund penalty when he attempted to take back funds he had advanced the failing corporation when he discovered there were unpaid payroll taxes.

The materials for the podcast can be downloaded at http://edzollars.com/2006-03-18_Payroll.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

Mar 17 2006

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Rank #5: That's Not Income, That's a Discount - The Ninth Circuit Corrects the Tax Court - Ed Zollars

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This PodCast is about the tax implications of a prepaid purchase discount that may need to be refunded if purchase goals are not met.  The issue has resurfaced as the Ninth Circuit Court of Appeals reversed the Tax Court in the case of Westpac Pacific Foods v. Commissioner.  The Ninth Circuit's views on this topic differ both from those of the Tax Court and the IRS, each of which has it own views on this topic.

In the podcast, the question to be addressed is what do we tell our clients who are faced with this issue? 

The materials for this podcast can be downloaded from http://edzollars.com/2006-07-08_Westpac_Advances.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

Jul 08 2006

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Rank #6: Indecent Exposure-Internet Access Security Issues Away From the Office - Ed Zollars

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This Podcast considers technical security issues that arise when you are traveling and take your laptop with you to "stay connected" with your office and clients.  There are a number of risks that have been discussed in recent weeks on Steve Gibson and Leo Laporte's Security Now podcast that I wanted to discuss in the context of a tax professional.

We look at how your system may be compromised and your data exposed rather easily by any other machine on a network you are connected to (incluidng a hotel high speed network or a wifi hotspot at your local coffee shop).  And by this I mean a machine of any other guest or patron of the shop, or just someone in distance of the hotspot.   As well, we discuss why wifi encryption does not address this problem, and why additional steps are necessary.  We also discuss the steps you can take to make your transmissions truly secure.

The materials for this podcast can be downloaded from http://edzollars.com/2006-05-20_Secure_Data.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

May 27 2006

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Rank #7: Is it Really My Loan? S Corporation Debt Once Again - Ed Zollars

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This Podcast is about the importance of following proper form in corporate debt situations.  A few weeks ago (back in April) we looked at the case of Ruckreigel where a taxpayer lost an IRS challenge on whether a debt was truly from the shareholders to the corporation due to a failure to follow the necessary formalities.  This week, the taxpayers strike back with a taxpayer victory in the case of Miller v. Commissioner (TC Memo 2006-125) where the IRS fails in its attempt to reclassify debt that followed the proper form but which the IRS attempted to claim was really debt from the bank to the corporation.

The taxpayer achieved victory on this point and the issue of whether the taxpayer was truly at risk as defined in Section 465, even though when all was said and done the taxpayer got out of all liability as the debt was actually paid by other investors who had guaranteed the entire loan structure.  This is an interesting case in showing the extreme importance of following proper form because, from an economic standpoint, the taxpayers in Ruckreigel seem to have much real exposure to potential loss than Mr. Miller actually ended up having, but he got his deduction.

The materials can be downloaded from http://edzollars.com/2006-06-23_S_Debt.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

Jun 23 2006

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Rank #8: It's a Matter of (Misplaced) Trust-Taxpayer Reliance on Advice - Ed Zollars

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This PodCast is about taxpayer advice and its reliability and its credibility in court.  Taxpayers get their advice from a lot of sources, and we often end up having to defend our own advice against other sources.  This week we have two cases that show that all advice is not created equal.  In the case of Lehrer v. Commissioner (TC Memo 2006-156) a taxpayer learned the hard way that selecting a preparer predominantly on which one computes the lowest tax is not necessarily the best way to end up well advised.

And the case of Diem v. Commissioner (TC Summary 2006-121) is useful for those clients that will try and check your advice by calling the IRS for an answer and then reporting the IRS's answer to you (so, you know, you don't have to do any work on that one).  Mr. Diem was clobbered when it turned out an IRS employee's assurance that the program offered by his employer would be treated just like the workers compensation style claim he was giving up for tax purposes turned out not to be so.

The materials for this week's presentation are found at http://edzollars.com/2006-08-03_Trust.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

Aug 04 2006

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Rank #9: The Tax GAAP-FASB Speaks on Tax Provisions for Financial Reporting - Ed Zollars

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This PodCast provides coverage of FASB's Interpretation 46 that deals with uncertain tax positions.  The new interpretation will create some real problems for CPAs, especially those who both handle tax matters and have any sort of attest relationship with the client (including compilations, reviews and audits) that deals with GAAP statements.

The materials can be downloaded from http://www.edzollars.com/2006-07-22_FASB_Podcast.pdf   , though the actual FASB interpretation needs to be downloaded from their site ( http://www.fasb.org/st/#int48  ) due to copyright issues-and you will want to download it.

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

Jul 21 2006

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Rank #10: Reasonable Cause for Late Filing - I Did Not Late File - Ed Zollars

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This PodCast concerns reasonable cause for late filing.  The logic of the application of the IRC to specific situations at times seems to defy common logic. Here, we look at a specific example of such.  In this case, the Tax Court decided that a reasonable cause for late filing that allowed a taxpayer to avoid the late filing penalty was that the court believed the taxpayer in reality had mailed the return on time, even if as a matter of law the return was late filed.  This is an extension of the issue discussed in the October 2005 podcast on proving timely filing.

The case in question is Gregorian v. Commissioner, TC Summary 2006-99.

The materials can be downloaded from http://edzollars.com/2006-07-15_Late_Filing.pdf .

Apologies for some of the audio glitches.  For various reasons, this week I used my Windows laptop to record the podcast--and, as should be clear, the machine proved "suboptimal" even though it used the same tools (hardware and software) as the old Mac iBook I normally use.  We'll be back on the iBook in next week's podcast.
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

Jul 15 2006

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Rank #11: Tax Increase Prevention Act of 2005-The Highlights and Lowlights - Ed Zollars

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This Podcast covers TIPRA , the Tax Increase Prevention Act of 2005.  We finally have a 2005 extender bill, albiet missing a few extenders and with a few surprises (some good, some not so great).  The President signed the bill into law this week, so it's time to look at the details that were in the bill.

The materials for this podcast can be found at http://edzollars.com/2006-05-20_TIPRA.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

May 19 2006

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Rank #12: What Did They Mean? Section 199 and Construction - Ed Zollars

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This Podcast is about construction costs.  We take a look at the regulations under Section 199 as they define construction found at Regulation 1.199-3(m).  These definitions are key for anyone who works with clients in construction related entities. 

The materials for this podcast can be downloaded at http://edzollars.com/2006-07-01_Construction.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

Jun 30 2006

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Rank #13: Keebler and Shenkman: Planning

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Bob Keebler and Marty Shenkman discuss planning between now and December 31st. The time is crucial and the opportunity is not to be missed. Marty has created a postcard to inform clients of 2012 planning opportunities. A company called "Printing for Less" - which does Marty's newsletter - will customize and mail it for any practitioner at a 20% discount off printing costs + postage. (Marty gets no payment from this). You can use his postcard primarily with no royalties (but a nice note and perhaps a gift to charity in Marty's name is in order). To learn more, just go to http://www.printingforless.com/shenkman and you can quickly handle the entire process. LISI has posted Marty's sample postcard and a flyer that explains it. You can find it by loging into LISI and looking under ActualText.

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

Oct 12 2012

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Rank #14: Keebler - Strategies for Mitigating Taxation of Concentrated Low Basis Positions

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How can a client reduce the potential tax burden where the holding in question is a large concentration of stock in one or two companies? Bob Keebler discusses Strategies for Mitigating taxation of concentrated low basis positions.

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

Sep 26 2011

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Rank #15: Paul Hood - S Corporation Tax Affecting

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Paul Hood - Tax Affect or not Tax Affect S Corporation earnings? Paul Hood discusses the issues. Is there a premium? Should you believe the Tax Court? Keep listening. Paul Hood will be hosting a 90 minute teleconference on September 28th titled ?A Method in the Madness: The Fine Art of Designing Estate Planning Tools and Techniques.? On this special teleconference, Paul will cover how proper plan design is really a 3-part analysis (the technique, the particular assets and the ?players? involved), and how to balance ?asset? factors such as valuation issues, intended use and management of assets, ease of transfer or division, availability as loan collateral and special tax attributes. Register by calling 866.754.6477 or online using this link: Paul Hood Teleconference .

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

Sep 12 2011

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Rank #16: Paul Hood - Discounts for Lack of Marketability When Controlling Interest Involved

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Business Valuation authority Paul Hood discusses valuation when a controlling interest in a closely-held corporation is involved. Paul is the co-author of a new book on business valuation - A Reviewer's Handbook to Business Valuation - that was the subject of our recent book review in Business Entities Newsletter # 127.

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

Sep 11 2011

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Rank #17: Paul Hood - Discounts for Built-In Capital Gains

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Paul Hood, co-author with Tim Lee of the recently published book, A Reviewer's Guide to Business Valuations, discusses recent cases involving valuation discounts for built-in capital gains.

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

Sep 10 2011

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Rank #18: Bob Keebler discusses Revenue Procedure 2011-41

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Bob Keebler discusses Revenue Procedure 2011-41, which was issued by the IRS on August 5th. Bob covers the safe harbor rules applicable when executors elect out of paying estate tax, as well as the rules on how-to allocate basis

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

Aug 10 2011

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Rank #19: Bob Keebler focuses on Notice 2011-66

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In this PodCast, Bob Keebler focuses on Notice 2011-66, the 1022 election not to pay estate tax, along with impact of Form 8939

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

Aug 10 2011

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Rank #20: Budget Control Act of 2011 Part 2 of 2

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In this PodCast, Bob Keebler focuses on the tax issues raised by the Budget Control Act of 2011, along with what Congress might do in in the future. Bob also reviews the things advisors should be doing to help their clients. This is Part 2 of 2

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

Aug 10 2011

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