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qualified real property business indebtedness (QRPBI)

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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Court of Appeals 9th Circuit reverses; home mortgage interest deduction limits apply per taxpayer

Court of Appeals 9th Circuit reverses; home mortgage interest deduction limits apply per taxpayer

Voss v. Comm., (CA 9 8/7/2015) 116 AFTR 2d ¶ 2015-5128 A divided Court of Appeals for the Ninth Circuit, reversing a Tax Court decision, has concluded that the Code Sec. 163(h)(3) limitations ($1 million of acquisition indebtedness and $100,000 of home equity indebtedness) are applied on a per-individual basis, and not a per-residence basis. […]

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Tax Court denies investment interest deduction in excess of qualified residence interest limit

Tax Court denies investment interest deduction in excess of qualified residence interest limit

Minchem International, Inc., TC Memo 2015-56 The Tax Court—while noting that the qualified residence interest regs allow debt exceeding the applicable limit to potentially be allocated to an otherwise deductible category of interest—has denied the taxpayers’ investment interest deduction because they failed to shown that the funds, which were from a loan secured by a […]

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Debt secured by interest in disregarded entity can be qualified real property business debt

Debt secured by interest in disregarded entity can be qualified real property business debt

In Revenue Procedure 2014-20, 2014-9 IRB, IRS has provided a safe harbor under which it will treat indebtedness of certain taxpayers, that is secured by 100% of the ownership interest in a disregarded entity that holds real property, as indebtedness that is secured by real property for purposes of the income exclusion under Code Sec. […]

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Debt secured by interest in disregarded entity can be qualified real property business debt

Debt secured by interest in disregarded entity can be qualified real property business debt

In a Revenue Procedure, Rev. Proc. 2014-20, 2014-9 IRB, IRS has provided a safe harbor under which it will treat indebtedness of certain taxpayers, that is secured by 100% of the ownership interest in a disregarded entity that holds real property, as indebtedness that is secured by real property for purposes of the income exclusion […]

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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