All Episodes
How Tax Works — 59 episodes
Substantial Economic Effect and Section 704(b) of the Internal Revenue Code
Penalties for Late Filed Forms 3520, 3520-A, 5471, and 5472
New York’s Pied-a-Terre Tax
The Curious Case of Kwong (and Adbo), and the Abatement of Interest and Penalties
Entity Selection Part II: Payroll Taxes in the Era of Soroban Capital Partners and Sirius Solutions
Substance v. Form Part III: Project Soy and the Economic Substance Doctrine
Cannabis, 280E, and (sort of) Rescheduling
QSBS Part VI: Why You Probably Shouldn’t Try to Qualify for the Exclusion Under Section 1202 of the IRC
Theft, Scam, and Casualty Losses
Ferraris, Montana LLCs, and Use Taxes
Hobby Losses and How They Are Limited
Unrelated Business Taxable Income
Substance Versus Form, Part II: The Step Transaction Doctrine
Substance Versus Form, Part I: The Economic Substance Doctrine
Stock Sales Taxed as Asset Sales
Common Mistakes and Misconceptions Regarding Qualified Small Business Stock (QSBS) Under Section 1202
Allocations Under IRC 704(c)
Offers in Compromise (OIC)
Payment Plans and Penalty Abatement
What You Should Do If Your Audit Goes Poorly and You Need to Litigate?
What Should You Do If You Get Audited by the IRS (or State Revenue Agency)?
Updates to Qualified Small Business Stock and R&E Expensing Under OBBBA
If You Win the Lottery, the First Thing You Should Do Is… Call a Tax Lawyer?
Grouping and Separate Activities Under Section 469 of the Internal Revenue Code
The Installment Method Under Section 453 of Internal Revenue Code
Can AI Replace Tax Lawyers? (Part II)
Can AI Replace Tax Lawyers? (Part I)
How I Think the ESPN and NFL Deal is Structured
Real Estate Investors and the Passive Activity Loss Rules under IRC 469
Famous and Important Tax Cases: Part II
Famous and Important Tax Cases: Part I
Family Offices
F Reorgs Redux
ABCs of A, B, and C Reorganizations
Partnership Divisions
Divisive Reorganizations
What the F is an F Reorg?
Golden Parachutes
Why Foreign Persons Probably Shouldn’t Own LLCs
Why, for Tax Reasons, You Should Buy a Professional Sports Team
Qualified Small Business Stock (IRC 1202): Part III
Qualified Small Business Stock (IRC 1202): Part II
Qualified Small Business Stock (IRC 1202): Part I
Questions People Ask Tax Lawyers at Weddings
Tax Issues with Divorce
At Risk Limitations under IRC 465
Passive Activity Losses and Credit Limitations under IRC 469
Self-employment Tax on Partners, Net Investment Income Tax, and Soroban Capital Partners LP v. Comm’r (Part II)
Self-employment Tax on Partners, Net Investment Income Tax, and Soroban Capital Partners LP v. Comm’r (Part I)
Tax Consequences of Forming, Selling, and Dissolving Partnerships and Disregarded Entities (Rev. Ruls. 99-5 and 99-6)
Various State and Local Income Tax Issues
Convertible Debt and SAFEs
Profits Interests, Promotes, and How to Structure Equity-based Compensation
Equity-based Compensation and 83(b) Elections
Ordinary & Necessary Business Expenses: Examples and What Not to Do
Ordinary & Necessary Business Expenses: IRC 162 and 212
Residency
Sales and Use Tax
Entity Selection