Guest Article Archives - Page 15 of 51 - Think Outside the Tax Box

Guest Article

By Ted Stotzer

Turning Intellectual Property into Interest Deduction Capacity: Use of an IP Holdco After the OBBBA

Many taxpayers have lived with a frustrating mismatch since the Section 163(j) limitation tightened after 2021 – the business may generate plenty of cash, yet its interest deductions are limited because adjusted taxable income (“ATI”) is too low, e.g., due to capex. The 2025 restoration of depreciation and amortization addbacks makes ATI planning relevant again, especially for groups that own valuable intangible property (“IP”), and the choice of legal entity to house group IP may have very different tax consequences as discussed in this article.

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TAX COURT ROUNDUP – February 2025

When we enter upon a new Administration, we wonder at the shape of things to come. But surely since 1916, we have never had an incoming Administration promise us a repeal of the income tax and the reestablishment of the import tariff as the principal source of Federal funding. I would not, however, immediately cease to follow the proceedings of the US Tax Court.

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Leaving the United States, Part II: Renouncing Your Citizenship

In Part I of this 3-part series, we discussed the tax ramifications of living abroad, becoming an expat. In Part II, we go to the extreme by leaving America and renouncing our citizenship. And as you would guess, there are tax consequences to such an action. Before we step into renouncing our U.S. citizenship, we need to address how we can lose our citizenship.

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Is Student Loan Forgiveness Taxable? It Depends…

Is student loan forgiveness taxable? Yes. No. Maybe. Sometimes. It primarily depends on the student loan forgiveness program. But like everything else with student loans, there are a number of other factors at play. Why make it easy when you can thoroughly confuse taxpayers, federal student loan servicers and financial planners for years to come? Keep reading to learn when student loan forgiveness might be tax-free and how to prepare your clients for taxable loan forgiveness.

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Attack On Hobby Loss Regulations

Dr. Gary M. Schwarz and Marlee Schwarz overall lost in a recent Tax Court decision. It was a fascinating story. Dr. Schwarz, who had a very successful dental practice, also had a substantial amount of real estate. On some of the real estate, deer larger than usual for Texas roamed thanks to a fencing system that Dr. Schwarz had invented. This allowed for an ecotourism operation, which included hunting packages that generated a lot of revenue, but even more expenses. The silver lining of that cloud was the losses, characterized as farming, sheltered other income from dentistry and real estate.

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Leaving the United States, Part I: Expats

When Americans speak of leaving America, they generally are expressing a desire to live elsewhere in the world for cultural reasons or due to cost of living. These people are called expatriates, aka expats. For clarity, a mere visit to another country does not make you an expat. To be an expat, the move needs to be long-term and often includes working or retiring in the new country. Expats live somewhere outside the U.S., but still have a tax obligation to the U.S. and possibly the country they move to. That will be the focus of this article.

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Tax Preparer Hit with Stiff Sentence

John Anthony Castro is a colorful character. He entered several Republican primaries seeking the Presidential slot after failing to win the primary for a Senate seat representing Texas. He sued to have our once and future President Donald Trump be removed from the ballot on Fourteenth Amendment Section 3 grounds. As we can easily infer, those suits went nowhere. But more than anything, John Anthony Castro was a tax guy with a virtual practice with locations in four cities. Not anymore. Now he is resident in a Bureau of Prisons facility – the Federal Medical Center Fort Worth. On October 30, 2024, Judge Terry Means sentenced Castro to 188 months in prison, followed by one year of supervised release and restitution of $277,243, following his conviction on 33 counts of “Aiding and Assisting in the Preparation and Presentation of a False and Fraudulent Return." Does the sad story of John Anthony Castro hold any lessons for us? Perhaps.

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Facebook Advertising for Accountants: Targeting Your Ideal Clients and Driving Conversions

As our digital existence expands, accountants must leverage every tool to reach potential clients and grow our practice. Facebook advertising is a robust platform that offers precise targeting options, retargeting capabilities, and various ad formats to drive conversions. In this article, I will provide a comprehensive overview of how accountants can use Facebook advertising effectively, covering ad creative, audience targeting, and budget optimization, along with practical examples to illustrate each concept.

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TAX COURT ROUNDUP – January 2025

No holiday break for US Tax Court, as fresh developments arise, and some old doctrines need reenforcing. As usual, we've got both common problems and arcana on the radar, with one potential blockbuster.

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