End of Circular 230 Disclaimers & Move Towards Reasonableness
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End of Circular 230 Disclaimers & Move Towards Reasonableness

ByJustin Hughes - JD, CPA, LLM

Summary Everyone is happy that Circular 230 disclaimers have been nixed in conjunction with the end of the Covered Opinion rules. The new Circular 230 rules covering written advice install a number of reasonableness inquiries, which utilize a new “reasonable practitioner” standard. The new principle based standards are “more straightforward, simpler, and can be applied…

Basic Considerations: Electing to Treat a Stock Purchase as an Asset Purchase

Basic Considerations: Electing to Treat a Stock Purchase as an Asset Purchase

ByJustin Hughes - JD, CPA, LLM

  Can you help your client obtain a “step-up” in a stock purchase? As a tax adviser, you may have been confronted with the following scenario: your client (P) is buying 100% of the stock of a corporation (T) from seller (S), but the purchase price far exceeds T’s basis in its assets. Since P…