Sorting Out Partner Payments
Congress enacted section 707 in 1954 to address the tax treatment of paymentsby a partnership to its partners and to distinguish such payments fromdistributive shares of partnership income.
The Tax Lawyer | Fall 2021
Volume 75, Issue 1
Articles
Section 265 Disallowance and the PPP Expense Nightmare
Through the CARES Act, Congress established a generous Paycheck ProtectionProgram (PPP). Under that program, recipients would get loans thatcould easily qualify for tax-free forgiveness.
The Role of Professional Organizations in Practice and Policy: How Lawyers Overtook Accountants and Economists in the Early 20th Century Tax Field
Tax policy and practice are inherently interdisciplinary, involving the closecollaboration of lawyers, accountants, and economists. But the presence andstrength of the legal profession in a field tha…
Federal Tax Ethics Rules and State Malpractice Litigation
In addition to rules of professional responsibility applicable to the practiceof law generally, some legal specialties have complementary ethical rules or guidelines tailored to the unique aspects of…
Employment Taxes in Crisis: In Practice, Enforcement, and Insolvency
When President Trump permitted the Service to defer employees’ SocialSecurity taxes in 2020 as a result of COVID-19, he claimed it was a “modest,targeted action.”…