Belan Wagner
Modifying an Option Agreement? It May Be Considered a New Agreement for Tax Purposes.
PAYMENTS RECEIVED UNDER OPTION AGREEMENT ARE NOT TAXED UNTIL EXERCISE OR LAPSE “An option is a contract which gives the Optionee a right to buy, sell, lease, or the like within a certain period of time.”[1] An option payment is not recognized as income at the time the payment is paid or received.[2] Instead, the […]
READ MORECompensation for a victim’s injuries in a personal injury accident is typically made by an insurance company. In California, insurance companies owe three duties to the person whom they have insured (the “policyholder”): (1) duty to defend a claim (or lawsuit) even if some or most of the lawsuit is not covered by the policy; […]
READ MOREThis article addresses the tax consequences arising from the relief or cancellation of debt (“Mortgage Relief”) arising from a foreclosure, short sale or deed in lieu of foreclosure (“PR Disposition”) or loan workout with respect to a debt (“Home Mortgage” ) secured by a taxpayer’s principal residence (“PR” ). Click here to download a PDF […]
READ MOREThis issue of the WKBK&Y newsletter addresses Family Limited Partnerships as Estate Planning Tools. For a while, practitioners can still use family limited partnerships or limited liability companies as vehicles to accomplish estate planning goals (both referred to as “FLPs” herein). While the IRS keeps litigating the validity of FLPs under a variety of theories […]
READ MOREAllocation of Debt Among Partners in Tiered Partnershipsc
This month’s newsletter focuses on allocation of debt among partners in tiered partnerships. Last month we reviewed the fundamentals of debt allocation under Section 752. This month we are going to look at a particular entity structure and discuss how the anti-abuse rules under Section 752 would apply. The structure is a limited partnership with […]
READ MOREIRC 752 – Allocation of Debt Among Partners
This month’s newsletter focuses on an oldie but goodie: IRC 752 — Allocation of debt among partners — the fundamentals. For various reasons, we have been called up on to consult with accounts on the allocation of liabilities among partners — remember those boxes you have to check on the K-1’s? Almost invariably the liability […]
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