Author Archives: Russ

Swallows Holding Decision Now Available

Posted on February 19, 2008 by Russ

The Third Circuit Court of Appeals ruling in Swallows Holding, Ltd. v. Commissioner is now available online. The summary of the ruling is: “This case, grounded in the principles of administrative law, requires that we review the validity of an … Continue reading →

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Foreign Taxpayers Better File on Time…

Posted on February 18, 2008 by Russ

…or at least within 18 months of their due date. Why? IRS regulations hold that if a foreign corporation files after that date they cannot take any deductions. Consider a hypothetical corporation, Foreign Company Ltd., which has US source gross … Continue reading →

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Fast Food Mogul to Sample 36 Months of ClubFed Cuisine

Posted on February 17, 2008 by Russ

Karl James is the former president of Golden West Taco, Inc., one of the largest franchises of Taco Bell (which is based here in Irvine). Back in 2000 Golden West Taco went into Chapter 11 Bankruptcy protection. Yet Taco Bells … Continue reading →

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States of Opportunity

Posted on February 17, 2008 by Russ

Last Tuesday, the Wall Street Journal ran an excellent editorial titled “States of Opportunity.” “But one reason to conclude that taxes are also a motivator is because the eight states without an income tax are stealing talent from other states. … Continue reading →

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Legislature Approves $1 Billion in Cuts; $13.5 Billion to Go

Posted on February 17, 2008 by Russ

California’s legislature sent a $1 billion bipartisan package of budget cuts to Governor Schwarzenegger; the Governator signed the package yesterday. The budget cuts will come primarily from school funding and from Medi-Cal (California’s medical program for low income individuals). Yet … Continue reading →

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Crack Tax Redux

Posted on February 17, 2008 by Russ

New York is facing a budget shortfall this coming year. Governor Eliot Spitzer has an interesting idea about how to fill the gap: a crack tax. I’ve written about these taxes before. Many states have these taxes (21 at last … Continue reading →

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One Last Electronic Filing Delay

Posted on February 17, 2008 by Russ

If you are going to file Form 982 you will not be able to electronically file until March 3rd. Form 982 is the new form that allows taxpayers to not have to claim canceled home mortgage debt as income. You … Continue reading →

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1031 Swaps for Vacation Homes

Posted on February 17, 2008 by Russ

The IRS gave the go-ahead to §1031 exchanges for vacation homes. Do note there are significant restrictions. If you own a second home and are considering a §1031 exchange, make sure you follow the restrictions. Joe Kristan has the details … Continue reading →

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Louisiana Loves Gamblers

Posted on February 15, 2008 by Russ

And that’s not a good thing. Assume you’re an amateur gambler. You add up your winning and losing sessions for the year, and find that you have $150,000 of wins and $100,000 of losses. You get to deduct the $100,000 … Continue reading →

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Taxing the Virtual World

Posted on February 14, 2008 by Russ

Let’s suppose you’re playing an online role playing game such as Second Life. You’ve accumulated quite a bit of virtual property, and have a stash of virtual money. James Doe offers you $5,000 for your virtual money and virtual property—that’s … Continue reading →

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