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Unified loss rules

CCA sheds light on what constitutes “value” for unified loss rule purposes

CCA sheds light on what constitutes “value” for unified loss rule purposes

Chief Counsel Advice 2015500334 In Chief Counsel Advice (CCA), IRS has held that where a member of a consolidated group sold its stock of a subsidiary at a loss in a transfer subject to the unified loss rule (ULR), the attribute reduction amount was properly computed using the amount realized on the stock sale, not its […]

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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