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Eleventh Circuit affirms lower court's holding that consulting partner's sale of Ernst & Young interest was taxable in year of sale despite temporary limitations on economic enjoyment

Fox Rothschild LLP
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USA
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April 22 2011

In U.S. v. Fort, 107 AFTR 2d 2011-739 (11th Cir. 4192011) a three-judge panel of the Eleventh Circuit upheld a federal district court's (Northern District of Georgia) decision, granting the Department of Justice, Civil Tax Division, summary judgment on that issue that under the constructive receipt doctrine, a consulting partner's sale of an interest in Ernst & Young was a fully taxable in the year the interest was sold to Cap Gemini in exchange for the stock

Court of Federal Claims renders interesting statute of limitations decision in Russian Recovery Fund Ltd

Fox Rothschild LLP
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USA
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November 28 2011

In Russian Recovery Fund, Ltd., 108 AFTR2d 2011-5494, the Court of Federal Claims ruled that the Internal Revenue Service may proceed with a collection action against a partner in a lower-tier partnership or “indirect partner” provided such partner’s return was filed within three years of the issuance of a final partnership administrative adjustment (FPAA) to the upper-tier partnership with respect to partnership level items that were adjusted

Eighth Circuit Court of Appeals gives service a major victory to recharacterize distributions from an s corporation to its shareholder(s) as wages for FICA purposes

Fox Rothschild LLP
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USA
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July 8 2012

In David E. Watson, P.C. v. Commissioner, 668 F.3d 1008 (8th Cir. 2012), aff’g 757 F. Supp. 2d 877 (DC Iowa) the Eighth Circuit affirmed a federal district court of Iowa’s decision recharacterizing a substantial portion of dividend distributions made by an S corporation to its sole shareholder as wages for FICA purposes

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Eleventh Circuit affirms lower court's holding that consulting partner's sale of Ernst & Young interest was taxable in year of sale despite temporary limitations on economic enjoyment

Court of Federal Claims renders interesting statute of limitations decision in Russian Recovery Fund Ltd

Eighth Circuit Court of Appeals gives service a major victory to recharacterize distributions from an s corporation to its shareholder(s) as wages for FICA purposes

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