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Tax “Angel”: Elizabeth Copeland Promotes Pro Bono In Texas

Written by Jenny Burnam, Super Lawyers on September 20, 2017

As seen in Super Lawyers. Nearly 10 years ago, Elizabeth Copeland established the State Bar of Texas’ Tax Court Pro Bono Program, offering free legal assistance to low-income taxpayers in trouble with the IRS. It now serves as a model for more than 20 states. It also has welcome side benefits. “I can promise you Read More…

Donating To Employees Affected By Hurricane Harvey

Written by Elizabeth A. Copeland on September 13, 2017

According to a recent estimate from the U.S. Chamber of Commerce, companies have pledged more than $157 million to relief efforts addressing the devastation of Hurricane Harvey¹. But when your own employees are the people in need of assistance, how can your company help without running afoul of the IRS? Disaster relief payments or gift cards given by employers Read More…

Strasburger Partner Elizabeth Copeland Nominated to U.S. Tax Court

Written by Strasburger & Price, LLP on August 4, 2017

Strasburger & Price, LLP (Strasburger) is proud to announce that President Donald Trump has nominated our partner Elizabeth A. Copeland, for Judge of the United States Tax Court. “The firm is incredibly proud of Elizabeth and her accomplishment,” said Dan Butcher, Strasburger’s Managing Partner. “This nomination confirms that she is one of the finest tax Read More…

BEWARE! Impact of New Tax Rules on Your Family Limited Partnership

Written by Strasburger & Price, LLP on July 10, 2017

Family limited partnerships (“FLPs”) are a common estate planning technique. They permit centralized asset management, provide liability protection, and create a mechanism by which one generation can transfer wealth to the next without giving up control. Like all partnerships, FLPs do not pay federal income tax. Instead, an FLP’s income is “passed through” to its Read More…

BEWARE! Tax Law Changes Are a Game-Changer for Your Partnership

Written by Katherine E. David, Elizabeth Copeland, Joseph Perera, Farley Katz on July 6, 2017

As seen in Texas Lawyer. Under new legislation and Department of Treasury audit regulations, partners can be stuck paying a higher tax rate or—worse—someone else’s tax liability. Partnerships and limited liability companies (“LLCs”) that are treated as partnerships for tax purposes are commonly referred to as “pass-through” organizations because the entities do not pay federal Read More…

It’s a Wonderful Life – Or is it? The Taxation of Crowdfunding

Written by Joseph Perera on July 25, 2016

Every holiday season, I, like many other Americans, watch Frank Capra’s classic, It’s a Wonderful Life. While the movie has a number of iconic scenes, the most heartwarming scene occurs at the end, as the citizens of Bedford Falls gather in George Bailey’s home and give him the money he needs to get out of Read More…

Partnership Audit Rules Changed Significantly

Written by Farley Katz, Joseph Perera, Katy David on July 22, 2016

On Nov. 2, 2015, the Bipartisan Budget Act of 2015 (BBA) became law. The BBA provides new rules that will replace the long-standing Tax Equity and Fiscal Responsibility Act of 1982 (TEFRA) and the Electing Large Partnership rules that previously governed partnership audits. Some minor changes were made by the PATH Act (Dec. 18). These Read More…

The Silver Lining: Deferring Tax on Insurance Proceeds after Storms

Written by Brooks Caston on May 4, 2016

The recent hailstorms and flooding throughout the Dallas, San Antonio and Houston areas[1] serve as another unwelcome reminder that severe weather is a constant threat to Texas grape growers’ crops and equipment as well as their bottom lines. While insurance proceeds can compensate for the damaged or destroyed property, grape growers might be unaware that Read More…

Tax Incentive for Export Sales

Written by James R. Browne on April 6, 2016

If your company is a profitable U.S.-based business engaged in sales of products or services to non-U.S. persons, it may be eligible for a tax incentive that can equate to up to 2% or more of the gross export sales. The incentive is known as the domestic international sales corporation, or “DISC.” This newsletter explains Read More…

UPDATE: Should Your Business Have a Captive Insurance Company?

Written by James R. Browne and Stanley Blend on March 17, 2016

We previously wrote about how a profitable business can use a captive insurance company arrangement as an effective and flexible business risk management tool that also provides potentially significant tax and asset protection benefits. In late 2015, Congress enacted legislation effective for tax years after 2016 expanding the benefits available to small captive insurance companies, Read More…

Is Qualified Small Business Stock an Overlooked Tax Windfall?

Written by James R. Browne on March 11, 2016

Congress recently made permanent a tax break for taxpayers who invest in qualified small business stock (QSBS), granting a 0% tax rate on the first $10 million of gain, or if greater, 10 times the taxpayer’s investment. One commentator declared QSBS an “overlooked tax windfall” and noted: “It’s no secret that small businesses have long Read More…

Texas Business Personal Property Tax Alert

Written by Sam Hallman and Moira Chapman on February 4, 2016

The Dallas Central Appraisal District (DCAD) is targeting trucking companies to assess Texas business personal property taxes, requiring fast action by a targeted company to timely respond and protect its defenses to the tax appraisal.  DCAD is specifically targeting companies that have a terminal or other physical location in its district, but that may not Read More…

PATH Act Imposes New Filing Requirement on I.R.C. §501(c)(4) Organizations

Written by Katherine E. David and R. Bradley Fletcher on December 30, 2015

UPDATE: On January 19, 2016, the IRS issued Notice 2016-09, which provides interim guidance regarding the I.R.C. §506 requirements. According to the Notice, the Treasury Department and the IRS intend to issue temporary regulations implementing the I.R.C. §506 requirements, and the due date for submitting the Initial Notification will be extended until at least 60 Read More…

Important New Audit Rules Change Taxation of Partnerships

Written by Farley P. Katz, Joseph Perera and Katy David on November 13, 2015

On November 2, 2015, the Bipartisan Budget Act of 2015 (BBA) became law. Buried in the BBA are new rules replacing the long-standing Tax Equity and Fiscal Responsibility Act of 1982 (TEFRA) and the Electing Large Partnership rules that previously governed partnership audits. These new rules turn established partnership tax law on its head. Under BBA rules, if a Read More…

Annual Symposium Tackles Tax Trends

Written by on October 8, 2015

Strasburger & Price LLP recently hosted its 29th Annual Tax Symposium featuring updates on Texas sales tax and net investment income tax laws, the importance of worker classification and business succession planning, alternative routes to tax-exempt status, how to report foreign assets, the tax aspects of equity incentive plans for certain businesses, the future of estate planning Read More…

Summer Updates: Identity Theft and Tax Administration

Written by Rachael E. Rubenstein on October 2, 2015

As seen in Procedurally Taxing (September 2015) Tax-related identity theft was a hot topic this summer.  Since I last blogged about it in May, the NTA released her Fiscal Year 2016 Objectives Report to Congress, alerting us to an upswing in the number of open identity theft cases in IRS inventory; a written report was Read More…

Should Your Business Have a Small Captive Insurance Company?

Written by Stanley L. Blend & James R. Browne on August 21, 2013

Obama Signs Taxpayer Relief Act of 2012

Written by on January 9, 2013

Political Activity and I.R.C. §501(c)(3) Organizations

Written by R. Bradley Fletcher on November 5, 2012

Year End Tax Planning for Business Owners -Gain Acceleration Strategies

Written by James R. Browne on October 23, 2012

Spousal Trust Planning for 2012: A Possible Solution to the Current Uncertainty

Written by R. Bradley Fletcher & John K. Round on June 6, 2012

The clock is ticking on the current estate and gift tax exemption. Unless Congress and the President act, the current estate and gift tax exemption amounts will decrease on January 1, 2013 to $1 million per person from the current $5.12 million per person. Many people are struggling with the issues of whether to take Read More…

Estate of Confusion: Vanishing Estate Planning Options

Written by on April 19, 2012

This year the gift, estate tax, and generation skipping tax rate is 35%, with each person having an exemption from these transfer taxes of $5.12 million for transfers during life or at death. By way of this exemption an individual can give away $5.12 million transfer tax-free. Barring Congressional action, these rates increase to 55% Read More…

IRS Issues New Form Requiring Disclosure of Foreign Bank Accounts and Assets

Written by Elizabeth A. Copeland & Farley P. Katz on April 12, 2012

For individual tax returns (Forms 1040) due to be filed in 2012 (due this year by April 17, 2012, unless extended), the IRS has issued new Form 8938, “Statement of Specified Foreign Financial Assets,” requiring the disclosure of certain foreign accounts and assets. Whether an individual is required to file this form is complicated, but Read More…

Estate Planning Opportunities Expiring Soon

Written by Martin I. Roos on December 6, 2011

When Congress passed the 2010 Tax Act last December, it gave taxpayers a two year window for some estate planning opportunities. The 2010 Tax Act increased the estate and gift tax exemption amounts to their highest levels ever ($5 million per person), and reduced top tax estate and gift rates to their lowest levels since Read More…


Written by on April 7, 2010

The fog is starting to lift as our clients begin to prepare their third round of Texas Franchise Tax Reports under the new Texas “margin tax” rules.  Tax professionals now have had two tax seasons to learn the intricacies of these new rules and to advise their clients how to plan and report within this Read More…

FIN 48: Avoiding the Roadmap Trap

Written by James R. Browne on December 4, 2009

Private companies are in the process of implementing FASB Interpretation No. 48 (“FIN 48”), which imposes radically new accounting rules for uncertain income tax positions.1 These companies need to be mindful that their FIN 48 workpapers may be subject to discovery by the IRS and other tax authorities. Those workpapers may provide tax authorities with Read More…

FIN 48 and Uncertain State Tax Liabilities; A Voluntary Disclosure Agreement May Help

Written by Daniel L. Butcher on November 19, 2009

The Financial Accounting Standards Board (FASB) recently reaffirmed its decision to require private companies to implement radically new accounting rules for uncertain income tax positions, effective for 2009 annual financial statements.1 For companies that do not pay taxes in all states in which they have sales, the new accounting rules significantly increase the risk that Read More…

Multi-State Tax Update

Written by Daniel L. Butcher on November 17, 2009

Seventh Circuit Affirms Narrow Application of Accountant-Client Privilege in Federal Tax Matters

Written by James R. Browne on July 2, 2009

In Valero Energy Corp. v. United States,1 the Seventh Circuit Court of Appeals recently held that the statutory accountant-client privilege did not prevent the IRS from obtaining discovery of documents generated by two accounting firms in connection with a corporate restructuring transaction. The Court narrowly interpreted the scope of the accountant-client privilege in two respects. Read More…

IRS’ New Offshore Bank Disclosure Program

Written by Farley P. Katz on June 17, 2009

The IRS has announced a new voluntary disclosure program for undisclosed foreign bank or brokerage accounts. This will allow taxpayers who have failed to disclose their ownership of such accounts, failed to file required information returns and/or failed to report income from such accounts, to correct those failures and thereby avoid criminal prosecution. In addition, Read More…

ARRA Temporary COBRA Premium Subsidy

Written by Luke D. Bailey on March 30, 2009

The American Recovery and Reinvestment Act of 2009 (“ARRA”)1 was signed into law by President Obama on February 17, 2009. Among its many provisions, ARRA contains a substantial temporary federal government subsidy for COBRA premiums when the COBRA qualifying event is an employee’s involuntary termination of employment.2 While ARRA’s COBRA premium subsidy provisions are a Read More…

Golden Parachutes Under IRC Sections 280G and 4999 — Rules, Strategies, and Tactics

Written by on February 3, 1999

Strasburger is called upon frequently to advise corporations and executives in the areas of executive employment contracts, severance agreements, and changes in corporate control. A substantial tax issue often involved in these engagements is the Internal Revenue Code’s “golden parachute” rules found in Code Sections 280G and 4999. Luke Bailey, a partner in the Dallas Read More…