The 752 Regulations are used in determining a partner’s economic risk of loss for partnership debt.  These regulations apply a test to determine economic risk of loss by reviewing what the economic consequences would be to each partner if the partnership liquidated.  Thus, the partners risk is examined as if the partnership went through a...Read More

In recent times, tax attorneys have seen a number of scams whereby individuals will use the IRS as a means by which to obtain information or money from people.  With the digital age and access to information these scams and identity theft, relevant to tax issues and the Internal Revenue Service has increased.  Recently the...Read More

How is an Offer in Compromise Calculated?  An offer in compromise should be considered a tax settlement with the Internal Revenue Service.  When a taxpayer owes money to the IRS, under certain circumstances the taxpayer can submit a proposal to pay less than the amount of tax due.  While many people know what an offer...Read More

Recourse and Nonrecourse Debt in an LLC  As a tax attorney and business attorney, John McGuire of The McGuire Law Firm works with partnerships regarding the impact of partnership debt and the impact of recourse and nonrecourse debt.  The article below outlines law to consider regarding partnership debt.  If you have a question regarding partnership...Read More

What Is A Tax Attorney?  A tax attorney primarily works with issues in regards to the application of the Internal Revenue Code and how federal and state tax law may affect or impact their client’s individual or business issues.  As a Denver tax attorney, John McGuire also holds an additional degree, called an LL.M. in...Read More

The Complete Liquidation of a C Corporation  Many business owners and shareholders of corporations will ask their tax attorney and/or business attorney, “what is a complete liquidation, and what are the tax implications to the C Corporation and the shareholders upon a complete liquidation?”  I always find it interesting, maybe even ironic that the term...Read More

FATCA Application to U.S. and Foreign Financial Institutions  A Denver tax attorney at The McGuire Law Firm can assist you regarding the FATCA provisions and application of these provisions.  Below is information related to U.S. and foreign financial institutions. U.S. Financial Institutions United States financial institutions (USFIs) in addition to other United States withholding agents...Read More

Effect of a Deficit Restoration Obligation  A deficit restoration obligation is a partner’s unconditional obligation within a partnership agreement to restore any deficit balance in their capital account when the partnership liquidates.  The presence (or absence) of a deficit restoration obligation within a partnership agreement impacts which partners can be allocated losses & deductions generated...Read More

Transfers of Property to a Corporation In Exchange for Stock  A Denver tax attorney and business attorney at The McGuire Law Firm can assist clients with the formation and structure of corporations.  The article below outlines the tax implications when contributing property to a corporation in exchange for stock. Many business owners inquire as to...Read More

Year End Tax Planning  Time moves fast, especially this time of year.  Soon we will be gathering for Thanksgiving feasts, and in what would seem like the following day, be celebrating the holidays and bringing on 2014.  Although, the up and coming holiday season makes many busy, this can also be a wonderful time of...Read More