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Business owners may have heard about economic substance from their business attorneys or tax attorneys.  The Economic Substance Doctrine is a “test” by which the Internal Revenue Service will review certain transactions.  As a Denver tax attorney John McGuire has dealt with the Economic Substance Doctrine first hand for a number of clients and this...
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An installment agreement with the Internal Revenue Service is an agreement whereby a taxpayer agrees to pay a certain amount of money on or before a certain day of each month to satisfy their outstanding tax debt with the IRS.  As a Denver tax attorney, John McGuire has established many installment agreements with the Internal...
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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...
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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...
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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...
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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...
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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...
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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...
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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...
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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...
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