Business Related Issues
Applicable Partnership Interest

Effect of the Build Back Better Act on Corporate and Partnership Taxation

On September 15, the House Ways and Means Committee voted to approve sweeping changes to the Internal Revenue Code through the Build Back Better Act, which proposals, if ultimately passed, will have a significant effect on the taxation of corporations and partnerships. We discussed the changes proposed to affect estate and gift taxation in an earlier article. In this article we explore the effect of the Build Back Better Act on corporate and partnership taxation.

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Scott St. Amand October 3, 2021
Business Related Issues
Corporations

De Los Santos v. Commissioner
156 T.C. No. 9

On April 12, 2021, the Tax Court issued its opinion in De Los Santos v. Commissioner, 156 T.C. No. 9. The underlying issue presented in De Los Santos v. Commissioner was whether the benefits (a split-dollar life insurance arrangement) received by the petitioners were received in their capacity as employees or shareholders, and, in turn, whether such economic benefits or taxable to the petitioner’s as ordinary compensation income or as a distribution under IRC § 301.

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Scott St. Amand April 12, 2021
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De Los Santos v. Commissioner
156 T.C. No. 9

On April 12, 2021, the Tax Court issued its opinion in De Los Santos v. Commissioner, 156 T.C. No. 9. The underlying issue presented in De Los Santos v. Commissioner was whether the benefits (a split-dollar life insurance arrangement) received by the petitioners were received in their capacity as employees or

Read More »
Scott St. Amand April 12, 2021