The U.S. Court of Appeals for the Eleventh Circuit upheld the imposition of 40 percent gross valuation misstatement penalties against an individual with almost 30 years of business experience Circuit Judge Frank Hull said that although a tax shelter can be legitimate, William Gustashaw Jr. participated in one that was not, and Gustashaw's level of…
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FATCA Causes Chinese to ditch US passports
The long arm of the American taxman has many wealthy mainlanders ruing the day they decided to get US citizenship, and more are considering trying to get rid of it. Formany wealthy mainland Chinese who immigrated to the US, an American passport is a genie that cannot be put back in the bottle. More and…
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Tax Court Reviews 11 Factors Indicating Valid Indebtedness and Recongnises Acquisition Indebtedness on Loan from a Related Party.
The Tax Court determined that an advance from a U.K.-based utility to its wholly owned partnership in connection with the partnership's acquisition of a U.S. utility company was a loan, not a capital contribution. Accordingly, the $932 million of payments made on loan notes was deductible by the partnership as interest. Acknowledging that the advance…
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Tax Court upheld the denial of Installment Agreement where Taxpayer was Not Compliant
The U.S. Tax Court upheld the denial July 24 of an installment agreement in a collection action against a Louisiana chiropractor for liabilities relating to 2006 and 2007 (Pace v. Commissioner , T.C., No. 9216-11L, T.C. Memo. 2012-211,7/24/12) The Taxpayer operated a chiropractic business through his wholly owned corporation, Dauntless, Inc. (Dauntless). Taxpayer filed his…
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