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Failure to submit form required by reg didn’t kill early gain recognition election

Failure to submit form required by reg didn’t kill early gain recognition election

PLR 201528001 In a private letter ruling, IRS has concluded that a taxpayer who wished to elect to recognize income in the year that he received property as compensation, notwithstanding the fact that the property was subject to a substantial risk of forfeiture when he received it, had effectively made that election despite the fact […]

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Final regs modify application of Code Sec. 382 segregation rules to small shareholders

Final regs modify application of Code Sec. 382 segregation rules to small shareholders

IRS has issued final regs, T.D. 9638, 10/21/2013; Reg. § 1.382-3, on the application of the segregation rules to public groups of shareholders in determining owner shifts and ownership changes for purposes of Code Sec. 382’s loss trafficking rules. The final regs, which affect corporations, generally adopt the proposed regs issued late in 2011, with […]

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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