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Thompson & Knight LLP
Dallas, Texas
T&K Tax Knowledge
Recent Activity
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Posted by Lee Meyercord and Mary McNulty Lee Meyercord was recently quoted in a Tax Notes Today article (subscription required) and a Bloomberg Law article (subscription required) on her testimony at the IRS hearing on the proposed partnership audit regulations. Meyercord testified at the IRS hearing on behalf of the... Continue reading
Posted Oct 5, 2017 at T&K Tax Knowledge
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Posted by Todd Keator and Murtuza Hussain In a recent case, Benjamin Avrahami v. Commissioner, 149 T.C. No. 7 (August 21, 2017), the Tax Court held that payments, including those to a microcaptive, were not for insurance and therefore were not deductible under Section 162. Furthermore, since less than half... Continue reading
Posted Oct 2, 2017 at T&K Tax Knowledge
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Posted by Todd Keator Todd Keator recently gave a presentation addressing Section 1031 exchange “drop & swap” (and “swap & drop”) transactions. A “drop & swap” colloquially refers to a 1031 exchange involving a partnership where the partners either complete individual 1031 exchanges at the partner level or some of... Continue reading
Posted Sep 7, 2017 at T&K Tax Knowledge
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Posted by Lee Meyercord and Mary McNulty Lee Meyercord recently gave a presentation at the 2017 State Bar of Texas Advanced Tax Law Course on the new partnership audit rules. The presentation discussed in detail the rules in the proposed regulations, which filled many of the gaps in the statutes... Continue reading
Posted Sep 6, 2017 at T&K Tax Knowledge
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Posted by John Cohn, Todd Keator, and Kathleen Gerber In a recent case, Grecian Magnesite Mining, Industrial & Shipping Co., S.A., v. Commissioner, 149 T.C. No. 3 (July 13, 2017), the Tax Court declined to apply the principles of Rev. Rul. 91-32 when determining whether gain realized by a foreign... Continue reading
Posted Jul 31, 2017 at T&K Tax Knowledge
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Posted by Mary McNulty, Todd Keator, and Lee Meyercord The IRS reissued the proposed regulations on the new partnership audit rules that were released in January but subsequently withdrawn in response to the Trump Administration’s freeze on new regulations. As noted by Mary A. McNulty in a Tax Notes Today... Continue reading
Posted Jun 14, 2017 at T&K Tax Knowledge
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Posted by Sharon Fountain, Russell Gully, Jason Loden, Jessica Morrison, Neely Munnerlyn, and Shelly Youree The IRS recently described new alternative substantiation guidelines for its Employee Plans Examination employees to follow when they audit hardship withdrawals from a 401(k) plan or 403(b) plan. Thompson & Knight's employee benefits group has... Continue reading
Posted Jun 6, 2017 at T&K Tax Knowledge
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Posted by Russell Gully and Jessica Morrison Overshadowed by the political drama surrounding the Affordable Care Act (ACA) is tax legislation enacted in December 2016 to make stand-alone health reimbursement arrangements (HRAs) available to employees of certain small employers. An HRA typically consists of an arrangement under which an employer... Continue reading
Posted Apr 3, 2017 at T&K Tax Knowledge
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Posted by Mary McNulty, Todd Keator, and Lee Meyercord On January 18, 2017, the IRS released unofficial proposed regulations on the new partnership audit rules in the Bipartisan Budget Act of 2015 (“BBA”). The rules are “unofficial” because they have not yet been published in the Federal Register. As observed... Continue reading
Posted Mar 2, 2017 at T&K Tax Knowledge
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Posted by Todd Keator On January 19, 2017, the IRS issued final regulations under Section 7704(d)(1)(E) regarding the scope of the qualifying income exception for publicly traded partnerships (“PTP”) engaged in activities with respect to minerals or natural resources. The regulations are available here. PTPs are treated as corporations for... Continue reading
Posted Feb 13, 2017 at T&K Tax Knowledge
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Posted by Mary McNulty, Todd Keator, and Lee Meyercord Mary A. McNulty was recently quoted in a Tax Notes Today article (subscription required) on the proposed Tax Technical Corrections Act of 2016 (available here), which makes technical corrections to the new partnership audit rules in the Bipartisan Budget Act of... Continue reading
Posted Jan 4, 2017 at T&K Tax Knowledge
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Posted by Mary McNulty, Todd Keator, and Lee Meyercord The Tax Technical Corrections Act of 2016 (available here) introduced recently makes technical corrections to the new partnership audit rules in the Bipartisan Budget Act of 2015 (“BBA”). The BBA repealed and replaced the 1982 Tax Equity and Fiscal Responsibility Act... Continue reading
Posted Dec 19, 2016 at T&K Tax Knowledge
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Posted by John Cohn In May, the IRS proposed regulations to require reporting foreign-owned domestic disregarded entities, ownership and the transactions in which they enter with related parties. See here. Yesterday, the IRS finalized these regulations (available here) making a few minor changes. Under current law, a wholly-owned domestic limited... Continue reading
Posted Dec 13, 2016 at T&K Tax Knowledge
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Posted by Sharon Fountain, Russell Gully, Jason Loden, Jessica Morrison, Neely Munnerlyn, and Shelly Youree The Internal Revenue Service recently announced the 2017 calendar year cost-of-living adjustments for limitations applicable to employee benefit plans qualified under the Internal Revenue Code. Thompson & Knight's employee benefits group has produced a client... Continue reading
Posted Nov 8, 2016 at T&K Tax Knowledge
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Posted by Todd Keator, Todd Lowther, and Jessica Kirk The IRS has issued guidance on disguised sales of property within partnerships. Generally, partners may contribute property to, and receive distributions from, a partnership without recognizing a gain or loss. But in certain circumstances, the Sections 707 and 752 regulations will... Continue reading
Posted Oct 20, 2016 at T&K Tax Knowledge
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Posted by Jana Benson, Dean Hinderliter, and John Cohn The Tax Court, adopting a narrow reading of the Internal Revenue Code, has held that, although the sale of Section 1231 property qualifies for capital gain treatment, the gain or loss attributable to the termination of a sale of Section 1231... Continue reading
Posted Oct 5, 2016 at T&K Tax Knowledge
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Posted by Bill Mureiko, Sarah Woodberry, and Tyree Collier The IRS recently issued proposed regulations under Section 2704 of the Internal Revenue Code dealing with the use of valuation discounts when transferring (during life or at death) interests in family limited partnerships (“FLPs”) and similar entities. FLPs and similar entities... Continue reading
Posted Aug 30, 2016 at T&K Tax Knowledge
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Posted by Bill Mureiko and Sarah Woodberry The IRS recently issued much-anticipated proposed regulations under Section 2704 of the Internal Revenue Code which, if finalized in their current form, would greatly limit the use of valuation discounts when transferring (during life or at death) interests in many types of family... Continue reading
Posted Aug 12, 2016 at T&K Tax Knowledge
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Posted by Todd Keator Todd Keator recently gave a presentation at the 2016 State Bar of Texas Tax Section Annual Meeting on the new partnership audit rules, with an emphasis on drafting issues in partnership agreements and other documents. The presentation also highlighted numerous issues raised by the Texas Tax... Continue reading
Posted Jun 28, 2016 at T&K Tax Knowledge
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Posted by Todd Lowther Todd Lowther was quoted in Tax Law360 (subscription required) about a June 20, 2016 opinion by the Texas Supreme Court in Southwest Royalties Inc. v. Hegar et al., No. 14-0743. The Texas Supreme Court rejected Southwest Royalties’ principal argument in the case that it should be... Continue reading
Posted Jun 22, 2016 at T&K Tax Knowledge
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Posted by Todd Lowther and Paul Yin On May 10, 2016, the Texas Attorney General, in response to a formal request by the Railroad Commission of Texas (the “RRC”), issued an opinion finding that the Texas Legislature repealed the tax on crude oil petroleum produced within the state during the... Continue reading
Posted May 11, 2016 at T&K Tax Knowledge
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Posted by Jason Loden The IRS has long held the position that an individual partner in a partnership may not also be an employee of such partnership for tax purposes. The IRS’s position had previously been unclear as to whether an individual partner in a partnership could also be an... Continue reading
Posted May 10, 2016 at T&K Tax Knowledge
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Posted by John Cohn The IRS announced this morning that it is proposing regulations to treat a foreign-owned domestic disregarded entity as a corporation for reporting its existence, its ownership and the transactions in which it enters with related parties. A wholly-owned domestic limited liability company generally is disregarded for... Continue reading
Posted May 6, 2016 at T&K Tax Knowledge
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Posted by: Bill Mureiko, Eric Reis, Sarah Woodberry, and Tyree Collier Bill Mureiko, Eric Reis, Sarah Woodberry, and Tyree Collier gave a presentation on March 2, 2016, regarding the legal, tax, and practical considerations relevant to buying or otherwise supporting the purchase and ownership of homes for trust beneficiaries. The... Continue reading
Posted Mar 3, 2016 at T&K Tax Knowledge
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Posted by Mary McNulty Mary A. McNulty was recently quoted in a Tax Notes Today article (subscription required) on some of the open issues and uncertainties under the new partnership audit rules enacted last November in the Bipartisan Budget Act of 2015 (the “BBA”). Mary also recently spoke on a... Continue reading
Posted Feb 22, 2016 at T&K Tax Knowledge