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Assignment of income

Court case: Transfer of royalties failed assignment of income and economic substance tests

Court case: Transfer of royalties failed assignment of income and economic substance tests

Salty Brine I, Limited, (CA 5, 7/31/2014) 114 AFTR 2d ¶ 2014-5109 The Court of Appeals for the Fifth Circuit has affirmed a district court’s holding that transfers of royalty interests owned by a partnership, to segregated accounts at an insurance company that were the investment vehicle of life insurance policies owned by companies related […]

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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