Tax
More Tax Articles
Insurance Coverage & Recovery
Beyond The Bright-Line Test: Rent-A-Center v. Commissioner – Long-Awaited U.S. Tax Court Decision Provides More Heat Than Light On What Constitutes “Insurance” Between Related Parties
In 1977, IRS issued Rev. Rul. 77-316,[1] which held that when a corporate parent insures risks with a wholly owned subsidiary, the transaction per se cannot be characterized as insurance for federal tax purposes because the risk shifting and risk distribution that the U.S. Supreme Court has...
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The $11.2 Million Conference Table: Business Aircraft Upgrade Creates A Large Tax Bill
The U.S. Tax Court denied an aircraft owner the “bonus” tax depreciation available for business aircraft because it did not have a conference table. Despite the adverse result, the case offers valuable lessons on how to use, and substantiate the use of, business aircraft for tax...
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A New International Tax System? Finding The Middle Ground
Editor: Tell us about your professional background. Larson: I’ve been at Marcum LLP for just over a year now. Prior to joining Marcum LLP, I spent almost 18 years at a Big Four public accounting firm, where I was a partner for five years, and then more recently at a regional firm based in New...
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