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Tax Attorney Discussion: Partnership’s Assumption of Liabilities

As a tax attorney and business attorney, John McGuire frequently works with a partner within a partnership who contributes property to a partnership such as an LLC and the partnership assumes the liability on the property.  When this occurs, a tax attorney will advise the contributing partner that their basis is decreased by the sum […]

IRC Section 752 Regulations Article by Denver Tax Lawyer

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 […]

How is an Offer in Compromise Calculated?

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 […]

Recourse and Nonrecourse Debt in an LLC by Tax Attorney

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 […]

5 Reasons to Hire a Denver Business Attorney

A business attorney can help you form the proper entity or entity structure based upon the needs of your business. Further, through this process, your business attorney can explain to you the different liability protections afforded different entities and the different tax implications to the business and business owners based upon the choice of the […]

The Complete Liquidation of a C Corporation

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 […]

FATCA Application to U.S. and Foreign Financial Institutions by Tax Attorney

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 […]

Effect of a Deficit Restoration Obligation by Tax Attorney

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 […]