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Understanding the FDII Deduction

C corporations with foreign-derived intangible income can benefit from a 37.5% deduction. This article provides guidance and dispels general misconceptions or mistaken impressions regarding this new deduction. Further, the article provides an overview of the FDII concepts and pertinent definitions and terminology, as well as practice tips and implications for claiming the FDII deduction, for which many comp ...

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Case Law: Valuation Experts Play Key Roles in Cases in Texas, Arizona

Top State Courts Consider the Value of Goodwill, the Legitimacy of the Income Method of Valuation In State of Texas v. Clear Channel Outdoor, the Texas Court of Appeals considers testimony from an expert regarding the income method of valuation for the billboards; in Walsh v. Walsh, the Court of Appeals of Arizona reassesses the realizable benefits of stock redemption value in a law firm, and determines the ...

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Federal Law Cases Review Mortgages, Broker Price Opinions

A Credit Card Debt is Settled, But Tax on DOI Income Still Due Judge Ruwe at the Tax Court finds petitioners owe tax on income from a settled credit card debt in Shepherd v. Commissioner, and a U.S. Bankruptcy Court for the Western District of Pennsylvania rules on the valuation of a mortgagee’s creditor’s secured claim in Buena Vista Oceanside, LLC., v. Optimum Bank ...

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Lawmakers Put S-Corporations in Their Sights

Congressional Democrats have proposed financing student-loan legislation by expanding payroll taxes on subchapter S corporations and partnerships. The bill would levy Social Security and Medicare taxes on all business income if the firm is engaged in professional services, such as investment advice, or if 75% or more of the gross income of the firm is attributable to three or fewer shareholders. Investment ...

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