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What To Watch Out For With Family Limited Partnerships
The story of Anne Milner Fields is one of the reasons family limited partnership (FLP) opinions appeal to me so much. Born in 1925, she grew up in a small town in Texas and then moved to Dallas where she got a job as a secretary and met prominent oil
Will AMT Make a Comeback After OBBBA?
Following Betteridge’s Law of Headlines, the answer to the question posed in the headline is, “no.” Actually — because we’re talking about taxes here — we can say the answer is never so definitive, so let’s change it to “probably not.” But it’s more complicated than it may seem.
Real World Ethics: What Happens When a Judge Doesn’t Understand Tax Law
We all know how messy tax returns can get when couples who used to file jointly divorce and there are children (and tax credits) involved. It’s often difficult to explain the rules surrounding Head of Household filing status and the various tax credits available to parent-clients who have separated or
Syndicated Easements: Fresh IRS Offer and the Perils of Post-BBA Gamesmanship
The IRS has issued a statement about a new settlement offer that is going out for conservation and historic preservation easement disputes. It is similar to previous offers, but there is one big difference. The partnership will not have to make a payment at the time that it accepts the
What To Watch Out For With Family Limited Partnerships
Will AMT Make a Comeback After OBBBA?
Real World Ethics: What Happens When a Judge Doesn’t Understand Tax Law
Syndicated Easements: Fresh IRS Offer and the Perils of Post-BBA Gamesmanship
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D&A Planning After the One Big Beautiful Bill Act
After 2021, whether an expenditure was deducted currently or recovered through depreciation often affected timing, but it typically did not create a meaningful advantage from a Section 163(j) perspective. The restoration of depreciation, amortization, and depletion addbacks in the computation of adjusted taxable income (“ATI”) has changed that analysis and created a new opportunity for taxpayers with actual or anticipated interest limitation exposure. As a result, taxpayers should reconsider whether certain expenditures that historically may have been deducted immediately can instead be capitalized into depreciable or amortizable property in order to improve their Section 163(j) profile.
What To Watch Out For With Family Limited Partnerships
The story of Anne Milner Fields is one of the reasons family limited partnership (FLP) opinions appeal to me so much. Born in 1925, she grew up in a small town in Texas and then moved to Dallas where she got a job as a secretary and met prominent oil man Bert Fields Sr. They married, and she lived the life of a socialite until he died in 1963. She consciously turned herself into a businesswoman, going so far as to take accounting courses. Having no children or grandchildren, she took her grandnephew, Bryan Milner, under her wing, paying for his education and mentoring him. In 2010, the year she turned 85, she made him executor of her estate and gave him a general power of attorney. He was also set to inherit the residue of her estate after some specific bequests. I really think we have the elements of a novel or a TV miniseries here, but we are tax people, so we are going to focus on how Anne’s estate tax was handled after she passed. It didn’t go well.
Tax Research in an AI World
It has never been harder to do quality tax research than at any time in my 43-year career in tax accounting. In the 1980s, when I was part-time in the industry, there was no internet. Since I was part-time, I ordered Publications 1132, 17, and 334. The rest I found at the library. A few hearty souls might even remember when the post office had stacks of tax forms for the public. Once I went full-time for the 1989 tax season I needed more resources. CCH was my tool of choice. I still used IRS publications and the library. My handy reference guide of choice was, and still is, the QuickFinder. I never used TaxBook much, but it is another good resource for general answers. Then came the internet. The promise was that we would have the world at our fingertips. And for the large part we did, only we forgot some things we would rather keep at an arm’s length. The internet slowly allowed us to replace rooms in our office filled with tax guides and forms with online resources. Law offices and accounting firms often wrote tax articles on narrow tax subjects. Research was easier than ever.
Then came AI.
