As I reported yesterday, the U.S. Supreme Court, in Texas Top Cop Shop, Inc. et al v. Merrick Garland, Attorney General of the United States et al., lifted the Fifth Circuit’s injunction, that had been preventing the government from
Larry's Tax Law
Larry's Tax Law, published by Foster Garvey PC, focuses on detailed analysis and commentary on federal tax law, with particular emphasis on Subchapter S corporations and their complex tax provisions. The blog covers legislative developments such as the One Big Beautiful Bill Act and its impact on business tax deductions, including bonus depreciation and automobile loan interest deductibility. It also provides insights into tax planning strategies, regulatory changes, and notable tax cases and rulings. The content is aimed at tax practitioners and professionals seeking to navigate nuanced tax regulations and optimize tax outcomes for clients.
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The Drama Surrounding the Corporate Transparency Act Has Now Reached the U.S. Supreme Court
By Larry Brant
I last reported on December 27, 2024, that the Corporate Transparency Act (“CTA”) hit yet another speed bump. The U.S. Court of Appeals for the Fifth Circuit (“Fifth Circuit”) put the CTA on ice as of December 24, 2024,…
A Journey Through Subchapter S / A Review of The Not So Obvious & The Many Traps That Exist For The Unwary: Part XIV – An S Corporation Is Not Always a Mere Extension of Its Shareholders
By Larry Brant
In this Part XIV of my multi-part series on some of the not-so-obvious aspects of Subchapter S, I explore a narrow aspect of Subchapter S that is often ignored or forgotten. An S corporation is not always a mere extension…
The Drama Surrounding the Corporate Transparency Act Continues – Not Only Were Santa Claus and His Elves Busy This Holiday Season, So Were the Court and the Litigants in the Texas Top Cop Shop Case
By Larry Brant
INTRODUCTION
On December 6, 2024, I reported that the U.S. District Court for the Eastern District of Texas, in Texas Top Cop Shop, Inc. et al v. Merrick Garland, Attorney General of the United States et al, issued a 79-page decision…
The Corporate Transparency Act Hits a Roadblock
By Larry Brant
I have yet again encountered another important development diverting me from my multi-part blog series on Subchapter S. Earlier this week, the Corporate Transparency Act (“CTA”) hit a massive obstacle. I feel compelled to report about it.
On December 3,…
What Is Likely the Last Chapter in the Wild Journey of the Washington State Capital Gains Tax Occurred on November 5, 2024, With Voters Getting the Final Say
By Larry Brant
The Wild Journey
I am taking time out from my multi-part series on Subchapter S to report on the Washington capital gains tax. As you know, I have reported in several prior blog posts on the numerous challenges confronting the…
A Journey Through Subchapter S / A Review of The Not So Obvious & The Many Traps That Exist For The Unwary: Part XIII – What Happens to a Shareholder’s Return When There Is an Error on the S Corporation Return?
By Larry Brant
Basic Rules
IRC § 6501(a) generally requires the IRS to assess tax within three (3) years after a tax return is filed by the taxpayer.
There are two (2) notable exceptions to this rule under IRC § 6501(c) and (e),…
A Birthday Greeting to the Tax Reform Act of 1986
By Larry Brant
The Tax Reform Act of 1986 (the “TRA 86”) was signed into law by President Ronald Reagan on October 22, 1986, exactly 38 years ago today. TRA 86 was sponsored by, among others, Representative Richard Gephardt (D-Missouri) in the U.S.…
A Journey Through Subchapter S / A Review of The Not So Obvious & The Many Traps That Exist For The Unwary: Part XII – A Reoccurring Theme: Don’t You Know That Keeping Adequate Business Records Is Required?
By Larry Brant
In this Part XII of my multi-part series on some of the not-so-obvious aspects of S corporations, I explore a consistent theme – taxpayers lose fights with taxing authorities when they fail to maintain adequate records. Keeping adequate records is…
You’re Invited – NYU 83rd Institute on Federal Taxation (New York and San Diego)
By Larry Brant
I am excited to share that the 83rd Institute on Federal Taxation (IFT) will be held in New York City on October 20-25, 2024, and in San Diego, California on November 17-22, 2024.
This year, I will present my latest…