I focus on business tax planning ... on both sides of the reasonable compensation issue, which is uncommon in the tax arena. Usually, the IRS is expected to argue one position and taxpayers ...

United States, 2020 WL 1966847 (April 24, 2020), a recent tax shelter decision ... determine whether there was a reasonable basis for the taxpayer’s position. This argument may frame later ...

JDA’s after-tax profit as a percentage ... that individuals in positions subordinate to Watson were paid significantly more in compensation. To quantify the amount of reasonable compensation ...

A member may prepare or sign a return when there is a reasonable basis for the tax return position and it is adequately disclosed. This is consistent with Circular 230’s requirements. As with all tax ...

A while ago, we wrote about Form 8275, Disclosure Memo, as a safety tool to avoid penalties by disclosing a position on a tax return for which the preparer and taxpayer believe they have reasonable ...

The Tax Court has used both the “independent investor test” and the “multiple-factor approach” to evaluate whether compensation is reasonable ... close to the assumed rate of return, a factor favoring ...