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Affiliated corporations

Recent proposed Code Sec. 385 (debt versus equity) regs would bring sweeping changes

Recent proposed Code Sec. 385 (debt versus equity) regs would bring sweeping changes

Preamble to Prop Reg 04/05/2016; Prop Reg § 1.385-1, Prop Reg § 1.385-2, Prop Reg § 1.385-3, Prop Reg § 1.385-4 If finalized, recently issued proposed Code Sec. 385 regs would introduce sweeping changes to the treatment of related-party indebtedness, including extensive due diligence and documentation requirements (which would be applicable to cash pooling arrangements). […]

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IRS rules on gross receipts test for treatment of affiliated subsidiary’s worthless stock

IRS rules on gross receipts test for treatment of affiliated subsidiary’s worthless stock

  PLR 201548003 In a private letter ruling (PLR), IRS has ruled that the common parent of an affiliated group of corporations can claim a worthless stock deduction on its wholly-owned subsidiary’s liquidation or conversion to a disregarded entity for federal income tax purposes. For purposes of the Code Sec. 165(g)(3)(B) gross receipts test, the […]

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Meet Paul Raymond

Meet Paul Raymond

Mr. Raymond is a sought after speaker in tax controversy law by many attorney, accountant, and business groups and at the request of the Internal Revenue Service, has presented programs at the IRS Nationwide Tax Forum, attended by tax professionals throughout the United States.

Additionally, he continues to be an active member in the Section of Taxation, American Bar Association, where he was the Past Chair of the Employment Taxes Committee.

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Member CA Bar Member Orange County Bar US Tax Court Attorney