At Buckingham & McGuire, LLC our Denver tax attorneys assist clients in resolving IRS debts, audits and other matters, as well as applying the tax laws to our client’s individual and business issues. All of our tax attorneys have obtained an additional degree in taxation known as an LL.M. Our additional knowledge and education in taxation not only helps resolve IRS issues, but allows us to better assist our clients regarding their business transactions, estate planning and overall tax planning.

Residency and Estate Taxes

What is the effect of an individual’s residency and the application of estate taxes?  This may be an issue that does not apply to you or your clients because you or your client is a citizen of the United States and thus the law is relatively clear that tax on the individual’s estate is subject to world-wide reach.  Once it is clear that your or your client is not a United Stated citizen a determination must be made upon residency, which will impact the reach of the Internal Revenue Code in regards to estate tax.

If based upon the facts and circumstances an individual is a resident of the United States for transfer tax purposes then the Internal Revenue Code will reach the world-wide assets of such individual’s assets regarding the transfer of such property regardless of where the property, properties or assets are located.  Furthermore, the individual will want to consider the application of the transfer tax laws of the state they are a resident in, or own property.

If the facts and circumstances show that the individual is a non-citizen and non-resident of the United States for estate tax purposes, the Internal Revenue Code would hold that transfer taxes should only apply to the individuals assets and property located within the United States, which may be referred to as United States situs property.

With the above being said, how does one determine residency for transfer tax purposes?  Believe it or not, Congress has not provided a specific definition for resident or non-resident.  The regulations provide somewhat of a definition using domicile as a concept.  The regulations state that a resident decedent is a decedent who at the time of his death was domiciled in the United States, and a non-resident decedent is a decedent who at the time of his death was domiciled outside of the United States.  See Regulations section 20.0-1(b)(1) and (b)(2).

Thus, we have narrowed (somewhat) our issue to defining what is domicile?  Generally, a person will acquire domicile in a place they are living (even for a brief period of time) given there is no present intention of leaving or removing themselves from the present location.  Thus, you could say domicile (at least for adults) could be established by physical presence in a place or location that is connected with the individual’s intent to remain in that location.  Generally, a child will take the domicile of their parent(s).  An individual will initially be considered domiciled where they are born and this domicile will continue until it is show to change.  Thus domicile may boil down to presence and intent.  Presence may be easier to prove and demonstrate than intent, as intent is inherently more subjective or likely to be so.

The above article was drafted by John McGuire.  John is a tax attorney and business attorney at The McGuire Law Firm focusing his practice on matters before the IRS, individual & business income tax matters and business transactions from formation and contracts to negotiations and the sale of business assets or interests.

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Passive Activities Discussed by Denver Tax Attorney

Many individuals do not understand passive activities & passive losses and the Internal Revenue Code Sections and Treasury Regulations that provide the tax law surrounding passive activities.  Further, you may not be aware that losses from passive activities may be disallowed or “suspended” so to speak.  John McGuire, is a tax attorney at The McGuire Law Firm and has prepared the article below to provide information regarding passive activities.

Passive activities would be considered business activities or other trade activities whereby you do not materially participate in the business.  Material participation involves regular, continuous and substantial involvement in the operation of the business or trade.  A common passive activity could be your involvement with rental properties and real estate.  Generally, rental properties and real estate activity is considered passive even if you are materially participating in the activity.  It is important to note that you may be considered a real estate professional and with such designation your rental activities may not be considered a passive activity. Below are some common questions and issues related to passive activities.

Who do the passive activity rules apply to?  The rules will apply to the following:

  • Individuals
  • Trusts (other than grantor trusts)
  • Estates
  • Closely held corporations
  • Personal Service Corporations

Although, the passive activity rules do not apply directly to a partnership, S corporation or grantor trust, it should be noted and understood how the passive activity rules can apply to the owners of these entities.

In general, a passive activity loss will be disallowed.  Your passive loss would be the excess of your passive deductions over the gross income from your passive activities.  Certain passive losses may be allowed, which are issues for a separate article.  So, if a passive loss is disallowed, what happens to the loss or do you ever get to use or take advantage of the loss.  In general, you may be able to take the disallowed loss or losses when you dispose of your entire and total interest in the property.  For example, assume you could not take certain losses from real estate due to your adjusted gross income or other issues.  When you do sell the property and dispose of your entire interest in that real estate whereby the loss has been disallowed, you may be able to claim the previously disallowed passive activity losses.  This is different from unused passive activity credits.  You cannot claim unused passive activity credits when you dispose of property with the unused credits.

You can contact The McGuire Law Firm to speak with a tax attorney regarding your individual and/or business tax matters.  In addition to his law degree, John McGuire holds an LL.M., which is an advanced degree in taxation. Mr. McGuire’s practice focuses primarily on tax issues before the IRS, individual & business income tax matters & law and business transactions.

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Contact The McGuire Law Firm at 720-833-7705 or https://jmtaxlaw.com/ to speak with a tax attorney in Denver, Colorado or Golden, Colorado.

 

 

IRS Audit Tip On Mileage Deduction

If you take mileage as a deduction on your income tax return, the IRS audit tip below may help you.  Many individuals will claim mileage as a non-reimbursed employee expense on Form 2106, or if self-employed, on a Schedule C, or the deduction may even be stated on another business income tax return.  Most individuals know that to substantiate the mileage deduction they need to keep a mileage log stating where they drove, the total mileage and other information such as the business purpose for the travel.  What many individuals may not be aware of is that the IRS may also request them to verify the total mileage driven on their vehicle with third party records.  This issue is discussed below in greater detail.

Recently, I was involved with an individual income tax audit with a client over multiple periods of 1040 Schedule C (self-employed) filings.  The individual drove a decent amount in their business and had taken the mileage deduction on multiple vehicles that were used for business purposes.  The individual had maintained mileage logs for each vehicle and properly claimed the deduction on their schedule C.  During the audit, the IRS examiner requested that the individual obtain maintenance records to substantiate the total miles driven in each vehicle during the year.  This request was not to produce a mileage log of business miles driven, but records from oil changes and other maintenance records to show and verify the total number of miles, personal, business and commuting, over the course of the year.  For example, the examiner wanted to see the report from Grease Monkey stating the total mileage on the vehicle and be able to track and substantiate the mileage driven to see if the business miles claimed appeared reasonable and within the total mileage driven on the vehicle.

After the above incident, it is apparent the IRS is not only requiring a mileage log, but some form of 3rd party document to verify that the miles claimed are in line with the actual miles driven.  This being said, in addition to maintaining a mileage log, it is apparent that taxpayers taking the mileage deduction would be best served by maintaining all reports and maintenance records to verify their mileage.  Remember this the next time you take your car to the shop for an oil change or any repair!  It is probably best to even make a copy of the maintenance records and maintain the document with your mileage log and other tax related documents.  Tell your mechanic to keep the receipt clean!

John McGuire is a tax attorney and business attorney at The McGuire Law Firm.  Mr. McGuire’s practice focuses on tax issues before the IRS, tax planning, business transactions and tax implications to his individual and business clients.

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How is my Settlement Taxed?

How is my settlement taxed?  If you are involved in a lawsuit and are anticipating compensation for damages, this is a question you may be asking yourself and it is important to understand the tax implications related to your settlement.  The article below has been prepared by John McGuire, a tax attorney and business attorney at The McGuire Law Firm to discuss the taxation of settlements for lost wages, lost profits and loss in value of property.  Please remember that this article is for informational purposes only and to consult directly with your attorney and tax advisors.

If your lawsuit is an employment related lawsuit for a claim such as involuntary termination or unlawful discrimination, the proceeds received for lost wages, severance pay or back pay are considered taxable wages and are subject to self-employment tax.  Thus, these settlement proceeds are subject to federal income tax, social security tax and Medicare tax.  Furthermore, these proceeds should be subject to withholding and therefore the payor (generally the employer) should issue a W-2 to reporting the wages or salary (income) and taxes withheld.  You would thereafter need to report this income on your 1040 individual income tax return.

What about lost profits from a trade or business.  Settlement proceeds received from lost profits will also be subject to self-employment tax and would be included in your business income.  Issues and facts may vary, but in general, proceeds for lost profit would be reported as income to your business as if the business had made the money.

What if your lawsuit involves property and the lost value of property or loss in value of property?  If the settlement amount for a loss in value of property is less than the adjusted basis in the property, than the settlement amount should not be taxable, but you need to remember to thereafter reduce the adjusted basis in the property by the settlement amount for future gain or loss determinations.  On the other hand, if the settlement amount you receive exceeds the adjusted basis in the property, this excess amount is income.  The income may be capital gain income, and a full discussion of this issue would be better served in a separate article.  You can review the instructions for Form 4797 and Schedule D, which discuss capital gain & loss, and the Sale of Business Property.

What if a portion of my settlement proceeds are allocated for interest?  Generally, the interest portion of the settlement would be taxable as interest income, and thus would subject to ordinary income tax.

What about punitive damages?  Punitive damages are generally considered “other income” and thus would be subject to ordinary income tax.Please note, you may be required to make estimated tax payments based upon your settlement amount, which you can review under IRS Publication 505.

John R. McGuire is a tax attorney and business attorney at The McGuire Law Firm.  John’s practice focuses primarily on tax issues & matters before the IRS, tax planning for businesses & individuals and business transactions and contracts from the formation of a business to the sale of a business.  John can be reached at John@jmtaxlaw.com

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You can contact The McGuire Law Firm to schedule a free consultation with a tax attorney in Denver, Colorado or Golden, Colorado.

Minimum Gain Chargeback Provisions

If you have reviewed partnership agreements or operating agreements for an LLC you have probably read provisions relating to Minimum Gain Chargeback.  That being said, the Minimum Gain Chargeback provisions may have put you to sleep, and may not even be practical based upon the facts and circumstances of the partnership.  However, Minimum Gain Chargeback provisions are important to understand if in fact they were to apply to your situation and circumstances.  The article below has been prepared by a tax attorney and business attorney from The McGuire Law Firm to provide an explanation of Minimum Gain Chargeback.

Minimum Gain Chargeback provisions deal with non-recourse debt and the allocations of non-recourse debt.  Such provisions are mandatory if the partnership wishes to allocate non-recourse deductions to the partners in any manner other than per the member’s pro-rata portion of capital interest in the partnership.  Therefore, it is important to identify when a Minimum Gain may be realized.  Minimum Gain occurs when deductions are claimed on property that decrease the partnership’s book basis in the property below the actual balance of the non-recourse debt on the property.  A situation whereby you may see Minimum Gain is when property is depreciated.  The depreciation will drive the partnership’s book basis of the property below the amount of the loan on the property.  When a partnership does have Minimum Gain, the Minimum Gain Chargeback is an allocation of the gain to the partners or members who have received the benefit of non-recourse deductions, or who may have received distributions from the partnership that can be attributed to the non-recourse loan.   In short, if a partner has received a benefit from the depreciation of property whereby they did not bear the economic risk of the loan to acquire the property (because the debt was non-recourse and not personally guaranteed), the benefit can be “charged back” to the partner.

So when does the “charge back” occur?  The deductions or distributions taken by the partners are charged back when the property that was subject to the non-recourse debt is sold, transferred or otherwise disposed of, or when there is a change in the character of the non-recourse debt.  A change in the character of the non-recourse debt could be the debt converted to a recourse liability or the debt being forgiven.

Now, the million dollar question: What is the amount of the charge back?  The partnership’s minimum gain is generally going to be the excess of the non-recourse liabilities over the adjusted tax basis of the property subject to or securing the non-recourse debt.  Perhaps an example will help illustrate this.   Assume J&J, LLC had purchased property for $200,000 and took $100,000 in depreciation on such property.  Thereafter, J&J LLC obtain non-recourse financing of $250,000.  The minimum gain would be $150,000, which is the non-recourse debt of $250,000 less the adjusted basis of $100,000.

It is important to remember that a partner is not subject to a charge back for monies they contribute to repay a non-recourse debt, and it is possible for the partnership to request a waiver of the chargeback under certain circumstances.

John McGuire is a tax attorney at The McGuire Law Firm whose practice focuses primarily on tax matters before the IRS, business transactions and tax issues as they apply to his individual and business clients.  In addition to his law degree, John holds an advanced degree in taxation (LL.M.).  Please feel free to contact John with any questions.

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Tax Matters Related to the Transfer of Property Through Divorce

When property is transferred because of a divorce, is the transfer of property taxable and what tax issues should be considered?  This is a common question when an individual is going through a divorce and begins to look at and consider the settlement agreement and terms the parties are discussing.  The article and information below has been prepared by a tax attorney to provide general information regarding common tax matters and issues related to a divorce, separation of property and payments made after the divorce may have been finalized.  Please remember to consult your divorce attorney and/or tax attorney to discuss the specific tax implications of your divorce proceedings and related agreements.

Perhaps the key Internal Revenue Code section regarding this matter is Section 1041.  In general, IRC Section 1041 holds that transfers of property from one spouse to another spouse (or a former spouse) is not taxable when the transfer of property is incident and through a divorce.  It is important to note that if through the divorce, the parties agree to sell property to a third party, or the court orders the sale of property to a third party, the transfer or sale would be taxed under the normal tax principals.  This is so because the sale or transfer of the applicable property is not considered to be a sale or disposition subject to the divorce.  The non-taxable transfer of retirement accounts such as 401(k)s and similar profit sharing plans requires a specific court order known as a Qualified Domestic Relations Order, which is often referred to as a QDRO.

What about alimony?  Is alimony taxable?  Yes, alimony payments will be taxable to the spouse that receives the alimony payment and is deductible by the spouse (payor) that is paying the alimony.  It is important for the parties to know that they can also opt out of payments being considered alimony.  The parties must specifically state in the divorce documents and instruments that the payment is not alimony and thus not taxable to the recipient and thus not deductible by the party making the payment.

What about child support payments?  Are child support payments taxable?  No, child support payments should not be taxable to the recipient, nor is the party making the child support payment allowed a tax deduction for making the payment.

For example, Jack and Jill are finalizing their divorce agreement and the agreement holds that Jack will pay to Jill $500 per month in maintenance and $700 per month in child support.  The $500 maintenance payment would be taxable income to Jill and a tax deduction to Jack.  The $750 child support payment would not be taxable to any party, and Jack would not be allowed a deduction.

Thus, in addition to consulting with a divorce attorney or family law attorney, you may wish to consult with a tax attorney regarding the tax implications of your divorce decree and settlement documents.

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Can The IRS Refile a Tax Lien?

Can the Internal Revenue Service refile a Notice of Federal Tax Lien?  This is a very important question if in fact the IRS has filed a tax lien on you or your business.  The answer, of which, greater detail is provided below, is yes, the IRS can refile a tax lien.  The article below has been prepared by John McGuire, a tax attorney in Denver, Colorado at The McGuire Law Firm.  Please remember to always discuss your tax issues and related questions with your tax attorney or tax advisor.

Some background and overview will assist in answering the question above and general procedures followed by the Internal Revenue Service.  A statutory lien arises when a taxpayer does not pay a tax debt after demand has been made.  If no notice of federal tax lien is filed, the duration of a statutory lien will depend only upon the collection statute.  When the Notice of Federal Tax Lien is file, the statutory lien is impacted by such lien notice.  A statutory lien is always extinguished when the collection statute expires, but a statutory lien can also be released through self-releasing lien language on the Notice of Federal Tax Lien.  The self-releasing lien language may apply even if the collection statute was extended, or perhaps suspended.

The main policy behind a self-releasing lien is to ensure the government’s compliance with certain laws.  Under Internal Revenue Code Section 6325, the IRS must issue a lien released within thirty days of the liability becoming legally unenforceable or the liability being paid.  The trigger for a self-releasing lien will coincide with the initial collection statute expiration date, which helps to ensure that the IRS property releases the tax lien within the period of time mandated by law.

When it is determined there is a need to continue the statutory lien and the Notice of Federal Tax Lien, Form 668Y is used to notify creditors (and the public) that the statutory lien and Notice of Federal Tax Lien remain in full force.  It is very important to note that the refiling of a tax lien can only occur while the tax liability can be collected upon, meaning the collection statute has not expired or the collection statute has been extended or suspended.  The IRS does not have to refile the lien though, even if the collection statute is open. Generally, the IRS will only refile the liens when there is a need to preserve the attachment of the statutory lien to certain assets and maintain priority lien position amongst other creditors.  When the lien notice is refiled Internal Revenue Code Section 6323(g) the IRS’ lien position is preserved.

All this being said, what is the refiling period?  The time the IRS has to refile a notice of Federal Tax Lien has a beginning and end date.  The refiling period is a 12 month period.  This one year period the IRS has to refile the tax lien is the one year period ending 30 days after the ten-year period following the assessment of the tax for which the lien was filed.  For example, if the tax was assessed on April 15, 2010, the refiling period would be April 16, 2019 through April 15, 2020. In short, the IRS has until 30 days after the collection statute expiration date to refile the lien.

The above article was prepared by John McGuire of The McGuire Law Firm.  As a tax attorney and business attorney, Johns practice focuses primarily on tax issues before the IRS, tax related opinions & advice and business transactions.

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Can I Plead The 5th Amendment Before the IRS

Can I plead the 5th during the course of my communications with the Internal Revenue Service?  This a common question I am asked by clients and taxpayers who may be under an IRS audit, IRS debt matter or other related tax issue.  The article below has been prepared to provide general information regarding this matter, and it is recommended that you consult your tax attorney regarding the disclosure of information to the IRS.

The 5th Amendment of the United States Constitution holds that a person should not be compelled to be a witness against themselves.  Thus, it is possible to plead the 5th Amendment in certain tax proceedings if answering a question would incriminate the summoned individual.  However, what a taxpayer should understand is that information, documents and other related evidence that has been produced voluntarily by the taxpayer (or another witness) who has been summoned, can be used against the taxpayer even if the information would be incriminating.

Internal Revenue Code Section 7602 authorizes the IRS to summon taxpayers and other third parties to testify as well as provide records, documents and information.  Although a summoned person can plead the 5th amendment regarding an inquiry or question that may tend to incriminate them, as stated above, this does not apply to documents that may have already been voluntarily provided to the IRS.  This is so because the government did not compel the summoned person to produce the information when the information was voluntarily produced.  In certain circumstances the actual act of producing and providing documents can incriminate an individual because the mere act of providing the documents is an admission that the documents and information actually exist.  Whether or not the actual act of production would incriminate an individual would be based upon the facts and circumstances of the actual case at hand, but, the person may have a valid argument using the 5th Amendment privilege against producing existing documents that were voluntarily created.

What about third parties who may have received information or documents from the individual that is asserting their 5th Amendment privilege?  If a taxpayer has transferred information and documents to a third party, the IRS can summon such individual, and the taxpayer cannot argue the 5th Amendment to prevent the summoned party from disclosing documents and information to the IRS.  This is because the 5th Amendment is personal and therefore only the taxpayer can assert the privilege.  That being said, what about when the taxpayer provides information to their tax attorney?  If the taxpayer would have been able to avoid producing the records prior to transferring them to their tax attorney, the attorney-client privilege will prevent the IRS from summoning the attorney given the records were transferred to obtain legal advice.

The above article has been prepared by John McGuire from The McGuire Law Firm.  Mr. McGuire is a tax attorney whose practice focuses primarily on tax issues before the IRS, tax law & planning and business matters.

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IRS Offer in Compromise Resource Page

The article below has been prepared to act as an IRS Offer in Compromise resource page whereby individuals can obtain necessary information regarding an IRS Offer in Compromise.  Please note, this information is not legal advice and should not supplement the advice of a tax attorney or tax professional.

What is an IRS Offer in Compromise?

An offer in compromise allows a taxpayer to settle their tax debt with the Internal Revenue Service for less than the total amount of tax owed.  Generally, the IRS will accept an offer in compromise if the offered amount by the taxpayer is the most the IRS could collect from the taxpayer within a certain period of time.

Offer In Compromise Pre Qualifier Tool

The IRS has an Offer in Compromise Pre Qualifier tool that can be very useful to taxpayers wondering if they would be eligible for an IRS Offer in Compromise.  The pre qualifier tool initially asks the taxpayer questions related to tax return filings, estimated payments and other tax payment & filing issues as well as bankruptcy (click for initial questions).  These issues could dictated whether or not a taxpayer is even eligible to submit an IRS Offer in Compromise.  Thereafter, the Offer in Compromise Pre Qualifier Tool asks financial questions related to income, expenses, assets, asset values and loans.  These financial questions break down a taxpayer’s equity in assets and disposable income which are the major factors considered by the IRS when accepting or rejecting an offer in compromise.

IRS Offer in Compromise Form

Form 656 is the form submitted to the IRS when submitting your offer in compromise.  Form 656 states the taxpayer’s information, the tax types and periods of which the taxpayer is attempting to settle, and perhaps most importantly, the offer in compromise amount and terms for payment.  In addition to Form 656, the taxpayer must submit the proper financial statement.  An individual taxpayer will submit Form 433A OIC, and a business taxpayer will submit Form 433B OIC.  If an individual has ownership interests in a business, the individual would likely need to file Form 433B for such business.

Where To Submit Your IRS Offer in Compromise

Your offer will initially be submitted to one of two offer in compromise units, which are in Memphis, TN and Holtsville, NY.  Where you live, will determine the office where you will file your offer.  The offer in compromise booklet provides the correct address based upon where you live.

What Decisions can the IRS make regarding my Offer?

The IRS can either accept, reject or return your offer.  Acceptance, of course would be preferred!  If the IRS rejects your offer, they may reject the amount, but agree to a larger amount and thus you may still be able to settle your tax debt.  You can also appeal the rejection by filing Form 13711.  The IRS will return an offer if, for example, the taxpayer is out of compliance.  You do not have appeal rights on a returned offer.

What Information is Public?

The IRS does make certain information regarding offers public.  Click, “information” for addresses of IRS offices with information open to public inspection.

Publication 594

IRS Publication 594 discusses the IRS collection process and may be useful to you as you are considering submitting an offer in compromise to the IRS.  Generally, submitting an offer to the IRS acts as a hold on enforcement.

If you have questions regarding the IRS Offer in Compromise process or your ability to settle a tax debt, you can discuss these issues with a tax attorney at The McGuire Law Firm.  A free consultation is provided to all clients.

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Initial Considerations Regarding a Corporate Acquisition

In any corporate acquisition, there are tax and non-tax issues, multiple business considerations and goals of the parties involved with the transaction.  The tax planning that is involved before, during and after the acquisition process may include many options and alternatives to achieve the tax and non-tax wishes and goals of the parties.  Thus, one of the most important steps in the planning process of a corporate acquisition is to discuss and review the party’s intentions and goals, which may include short term matters and long term matters.

First, we need to identify the parties.  In any corporate acquisition you will have the buyer who is looking to acquire one or more businesses that are operated and owned by another business.  The seller, which may be referred to as the “target” or “target-corporation” may wish to be disposing of the business in exchange for some type or form of consideration, or merge in some way with the buyer.  Broadly stated, the buyer may wish to purchase the stock of the target corporation, or acquire the assets of the corporation.  Thus, in general, you can consider the purchase options to be a stock purchase or asset purchase of the target.  Furthermore, there is the possibility that the acquisition could be a hostile acquisition.  A hostile acquisition involves the acquisition of a publicly held company, like Wal Mart.  The acquisition begins without any agreement between the purchaser and the target corporation.  It is possible that through a hostile acquisition, the target may not even wish to be acquired or purchased by the buyer.

It is likely that the single most important factor in an acquisition will be the consideration to be paid or consideration received by target (property, stock and other items could be used as consideration).  Thereafter, an important issue to consider and understand is whether the shareholders of the target corporation plan to or wish to have an equity ownership in the combined entity after the acquisition is completed, or if such shareholders wish to sell their entire ownership interest in exchange for a cash payment or other financial benefit.  This issue will likely dictate the overall consideration involved and will, in many respects, control the overall structure of the transaction as well as the characterization of the transaction for tax purposes (taxable versus tax free).  For example, if the parties wished to have a tax free reorganization, a common theme in a tax free reorganization is continuing ownership interest in the combined business by the previous shareholders of the target business.  The transaction may only be able to qualify as a tax-free reorganization if a substantial portion of the consideration paid is the stock of acquiring corporation, or perhaps the stock of the acquiring corporation’s parent.  Thus, consider whether or not the target shareholders receiving shares of the acquiring corporation would be practical if in fact the some or all of the target shareholders wished to receive cash consideration for their ownership interests.  This example illustrates how the goals and wishes of the parties involved can dictate the transaction structure and thus the tax implications to the parties.

The above article has been prepared by John McGuire of The McGuire Law Firm.  As a tax and business attorney, Mr. McGuire’s practice is focused on tax planning, tax matters before the IRS and business transactions from business start-ups & formation, to business contracts & acquisitions.  You can schedule a free consultation with a business attorney at The McGuire Law Firm by calling 720-833-7705.

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