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original issue discount (OID)

Final regs cover broker reporting on debt instruments & on OID on tax-exempt obligations

Final regs cover broker reporting on debt instruments & on OID on tax-exempt obligations

T.D. 9750, 02/17/2016, Reg. § 1.6045-1, Reg. § 1.6045A-1, Reg. § 1.6049-10 IRS has issued final regs that provide guidance on information reporting by brokers for transactions involving debt instruments and options, including the reporting of original issue discount (OID) on tax-exempt obligations, the treatment of certain holder elections for reporting a taxpayer’s adjusted basis […]

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Tax Court denies life insurance company benefits from SILO & LILO transactions

Tax Court denies life insurance company benefits from SILO & LILO transactions

In a voluminous opinion, the Tax Court in John Hancock Life Insurance Company, etc., et al., v. Commissioner, (2013) 141 T.C. 1, has denied a life insurance company various deductions and tax benefits claimed in association with lease-in-lease-out (LILO) and sale-in-lease-out (SILO) transactions. After analyzing a number of test transactions, the Court found that 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