Gary Edelson
Visit Attorney ProfileWatch Out For Sales Tax
The Pennsylvania Sales Tax is imposed upon each sale at retail of tangible personal property and a few selected services. The Use Tax is imposed upon the use within the Commonwealth of Pennsylvania of tangible personal property purchased at retail and a few selected services… Read More
Tax Reform Actions That May Be Taken Before December 31, 2017
It’s the holiday season and everyone has plenty of items on their “to do” list. The proposed tax reforms have created additional items to add to your list that you may consider completing before December 31 (of course subject to a bill actually passing)! The… Read More
If you want a charitable deduction for a gift of property to a charity, you must avoid imposing restrictions upon the charitable donee
IRC §170(a) allows a deduction for any charitable contribution made during the taxable year. IRC §170(c) defines a charitable contribution to include a contribution or a gift to or for the use of qualified entities. A contribution is not deductible unless it constitutes a completed… Read More
Branch Transactions – New Aggregation Election
Do you have a business that has a branch in a foreign country? If so, new regulations will dictate how you determine your taxable income. Many businesses have a branch in a foreign country. This may include conducting business in the foreign country through an… Read More
Final Section 987 Regulations for “Qualified Business Units”
In December of 2016, the Treasury issued final and temporary functional currency regulations that apply to certain types of so-called “qualified business units”. A qualified business unit or “QBU” includes a corporation. In addition, activities of a corporation or an individual qualify as a QBU… Read More
New Disguised Sale Rules
One way of cashing out business assets involves contributing the business assets to an entity classified for tax purposes as a partnership in exchange for a minority interest in the partnership, where the partnership would borrow money on a full recourse basis and distribute the… Read More
Stay in LLC Structure and Go Public Using an UP-C Structure
In the “old days” if your business was in an LLC classified for tax purposes as a partnership and you thought you wanted to take your company public, you were told by the investment bankers to convert your LLC to a corporation. Many new businesses… Read More
Professional Corporation that does not elect subchapter S – be careful of using yearend bonuses to zero out taxable income
Some professional entities are C corporations. The case of Brinks Gilson & Lione, a professional corporation v. Commissioner, TC Memo 2016-20, points out the danger in operating a professional entity as a C corporation. In Brinks, the professional corporation had a substantial number of attorneys… Read More
It’s Tax Time – Wake Up and Think About Taxes!
Sometimes it is better tax wise to rehab space than build new. The Protecting Americans from Tax Hike Act of 2015 or “PATH Act” provided several gifts to the real estate industry that favors rehabbing older buildings. The PATH Act retroactively restored and made permanent… Read More