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Personal Holding Company

Tax Court uses asset, rather than income, approach to value interest in personal holding company

Tax Court uses asset, rather than income, approach to value interest in personal holding company

in Estate of Helen P. Richmond, TC Memo 2014-26, the Tax Court, using a net asset value method and then applying various discounts, has determined that a decedent’s 23.44% interest in a family-owned personal holding company was worth over $6.5 million for estate tax purposes. The Court rejected the estate’s lower value, which was determined […]

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CFC’s software income was foreign personal holding company income

CFC’s software income was foreign personal holding company income

In field attorney advice, 2013-2702F, IRS has determined that: (a) income earned by a controlled foreign corporation (CFC) from software it provided to customers was rental income; and (b) that income was foreign personal holding company income (FPHCI) that does not qualify for the FPHCI “active leasing exception.” Facts. The taxpayer CFC transfers software to […]

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Meet Paul Raymond

Meet Paul Raymond

Mr. Raymond is a sought after speaker in tax controversy law by many attorney, accountant, and business groups and at the request of the Internal Revenue Service, has presented programs at the IRS Nationwide Tax Forum, attended by tax professionals throughout the United States.

Additionally, he continues to be an active member in the Section of Taxation, American Bar Association, where he was the Past Chair of the Employment Taxes Committee.

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Member CA Bar Member Orange County Bar US Tax Court Attorney