Live 2-Hour Webinar: §168(k) Bonus Depreciation

Newly Unveiled Final Regulations. Unshackling Guidance, Compelling Choices.

With Bradley Burnett

Wednesday, Oct. 23
8 a.m. PT, 9 a.m. MT, 10 a.m.CT, 11 a.m. ET
(2 hours, 2 CPE)

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Congress radically overhauled §168(k) in the Tax Cuts Jobs Act (TCJA) on 12/22/17. Treasury took a somewhat harsh stab at guidance via proposed regs on Aug. 8, 2018. More recently, IRS issued a Rev. Proc. granting late election relief and, then, wallah!!

Final regs and a new batch of proposed regs broke loose on Sept. 13, 2019. What new adventures await?

What you will learn:

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There’s a New Sheriff in Town… at the IRS

Rettig

Can He Turn the Gaming Tables Upside Down?

By Bradley Burnett

For the longest time, saving employment taxes by means of skimming cash from either a partnership or an S Corp seemed a bit like the lawless wild west with no sheriff, no posse and no hanging tree. Oh, don’t get me wrong. There were laws on the books. It’s just that the odds of getting caught were slim to none, save for the stray example IRS or an occasional court made of some renegade that got caught.

But, there’s a new sheriff in town. Charles Rettig, the newly minted IRS commissioner, is at the helm. Under his watch, IRS this spring launched a new partnership reasonable-compensation audit guide. IRS also convinced the Tax Court it does not any longer have jurisdiction to hear S Corp reasonable comp employment tax cases (8th Circuit agrees). Evidence is on the horizon IRS plans to exact a mighty pound of flesh in response.

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Tax Update: Changing Water to Wine

'Dealer Intent' converted to 'Investor Intent' midstream – Ta Da!!
And other pulling-rabbits-out-of-hats stories.

By Bradley Burnett
Federal Tax Update

There is a long-standing story about a man changing water to wine at a wedding. Not a bad deal. And, pretty economical at that. Recently, a Houston area real-estate developer pulled off pretty much the same thing. And saved about $1.9 million in income tax as a result.

Our “pulling-rabbits-out-of-a-hat” story begins long ago with an 883-acre oilfield southwest of Houston. A real estate developer bought it in 1998 with visions of subdividing into residential and commercial lots and making millions. For 10 years, Sugar Land Ranch Development, LLC (SLRD) cleaned up the oil field, built a levee to keep the nearby Brazos River under control and agreed to a development plan with the city of Sugar Land. But, no dividing into lots or construction ever took place.

So far, so good.

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TCJA UPDATE: Alimony Planning Gets the Wrecking Ball

Margarita, alimony or both?

By Bradley Burnett
The Bradley Burnett Federal Tax Update

Did you, in high school or college, ever wait until the night before to write an important paper? I did. Needless to say, it wasn’t my best effort.

Catch Bradley Burnett's next live 3-hour webinar on "How to Avoid Being Crushed by Income Tax Collection from a Partnership: The New Centralized Partnership Audit Rules," on Nov. 7. Register | Learn More

It’s a bit like that with Congress and the hurriedly written Tax Cuts Jobs Act. The lion’s share of its 1,050 pages was written or overhauled in its last 12 days. That’s too fast.

And, it’s a wrecking ball on our ability to interpret what much of the law means.  Or, like pulling the rug out from a house of cards.

One such hastily, shoddily drafted new provision targets the alimony deduction.

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The New Small-Business Loophole You Can Drive a Truck Through

Loophole Arrow Crashing Through Maze Avoid Paying Taxes CheatingCapitalize or expense? New IRS 'de minimus' rule opens the floodgates.

By Bradley Burnett
Tax Practice

The issue is as old as the hills in the federal tax law. At least more than a hundred years old and that’s longer than most of us have been around. Old as old can be, and yet the latest version of the issue packs about as much sizzle and punch as you can get. Step right up and get your tickets here. Wait, you don’t have to buy a ticket from anyone. You can put on your own show right here, right now and, for that matter, most anytime you like.

Catch Bradley Burnett's upcoming webinar, "2016 Federal Tax Update for Closely Held Businesses," June 21, 2016, 1-2:40 pm ET 

What are we talking about? Most taxpayers want to write off expenditures right now. On this year’s tax return. IRS wants to slow tax write-offs down – to deny a current deduction and make the taxpayer delay by forcing the spread of deductions over time. It’s like a Tom and Jerry cartoon. It’s one of the oldest shows on the books. And, it’s the same story over and over and over and over.

That’s what makes IRS’ latest move in the saga so surprising. It’s like now the scriptwriter lets the cat blow the mouse to smithereens over and over and over and over. The cat finally outsmarts the mouse, or something like that. And, it is the mouse who authored it all.    READ MORE →