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MACRS depreciation

Field Advice – No partnership existed for tax purposes because there was no risk of loss or chance of gain

Field Advice – No partnership existed for tax purposes because there was no risk of loss or chance of gain

Legal Advice Issued by Field Attorneys 20161101F In a highly redacted Legal Advice Issued by Field Attorneys (LAFA), IRS has concluded that a taxpayer’s investment in an arrangement which was to provide it with Code Sec. 45 refined coal production tax credits wasn’t a bona fide partnership. The purported partner did not engage in a […]

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IRS announces latest reduction of refundable corporate AMT credits due to sequester

IRS announces latest reduction of refundable corporate AMT credits due to sequester

irs.gov/Businesses/Effect-of-Sequestration-on-the-Alternative-Minimum-Tax-Credit-for-Corporations On its website, IRS recently announced that corporations electing under Code Sec. 168(k)(4) to “swap” bonus and accelerated depreciation for an increased alternative minimum tax (AMT) credit limitation will see a 6.8% reduction in the amount of the refundable portion of these credits. The reduction is a required “sequestration” spending cut under the Balanced […]

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Late election out of exempt status for MACRS purposes ok’d even though election year is closed

Late election out of exempt status for MACRS purposes ok’d even though election year is closed

PLR 201508007, PLR 201508006, PLR 201508005, PLR 201508004   In a series of similar private rulings, IRS allowed taxpayers to make a late election not be treated as a tax-exempt entity for MACRS depreciation purposes even though the year in which the election should have been made was closed. The late election was allowed because […]

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IRS Rules on Depreciation of Outdoor Advertising Displays Reclassified as Real Property

IRS Rules on Depreciation of Outdoor Advertising Displays Reclassified as Real Property

PLR 201450001   In a private letter ruling, IRS has concluded that where a builder of outdoor advertising displays makes an election under Code Sec. 1033(g) to change its treatment of those displays from personal property to real property, 1) the displays are to be depreciated under a rule that applies when there is a […]

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Modification of automatic accounting method change rules for tangible property dispositions

Modification of automatic accounting method change rules for tangible property dispositions

Rev Proc 2014-54, 2014-41 IRB In a Revenue Procedure, IRS has provided guidance on making automatic accounting method changes that coordinates with recently issued final regs on dispositions of tangible property. Among other things, IRS made a number of modifications to Rev Proc 2011-14’s Appendix and allowed for a late partial disposition election under Reg. […]

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Final regs make changes for multiple/general asset account MACRS property dispositions

Final regs make changes for multiple/general asset account MACRS property dispositions

T.D. 9689, 08/14/2014; Reg. § 1.165-2, Reg. § 1.168(i)-1, Reg. § 1.168(i)-7 , Reg. § 1.168(i)-8, Reg. § 1.263(a)-3, Reg. § 1.1016-3 IRS has issued final regs on the disposition of Modified Accelerated Cost Recovery System (MACRS) property. The final regs, which largely follow 2013 proposed regs, make two changes to the proposed regs, including […]

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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