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Reasonable compensation

Internal IRS guidance provides insight on reasonable compensation and R&E

Internal IRS guidance provides insight on reasonable compensation and R&E

Legal Advice Issued by Field Attorneys 20154501F In Legal Advice Issued by Field Attorneys (LAFA), IRS highlights significant case law and other considerations it finds instructive in applying the reasonable compensation test under Code Sec. 162, determining what constitutes research or experimental (R&E) expenditures for purposes of the credit for increasing research activities, and applying […]

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Court rejects straight gross receipt analysis for S corp’s shareholder’s reasonable wages

Court rejects straight gross receipt analysis for S corp’s shareholder’s reasonable wages

In a Summary Opinion, the Tax Court in Sean McAlary, Ltd. v. Commissioner, T.C. Summary Opinion 2013-62, has determined the reasonable compensation of the president, secretary, treasurer, sole director, and sole shareholder of an S corporation engaged in the real estate business. The Court, rejecting a salary amount proposed by IRS’s expert based solely on […]

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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