Comments for rroyselaw.com Blog http://rroyselaw.com/blog1 Mon, 21 Nov 2011 18:44:14 +0000 http://wordpress.org/?v=2.8.4 hourly 1 Comment on Franchise Tax Board Audits Sale of S Corp in 338(h)(10) Transaction by Fred Koenen http://rroyselaw.com/blog1/2011/11/07/franchise-tax-board-audits-sale-of-s-corp-in-338h10-transaction/comment-page-1/#comment-3097 Fred Koenen Mon, 21 Nov 2011 18:44:14 +0000 http://rroyselaw.com/blog1/?p=82#comment-3097 A very good explanation of a commonly-overlooked problem with sales of privately-held businesses conducted as a sale of assets. A very good explanation of a commonly-overlooked problem with sales of privately-held businesses conducted as a sale of assets.

]]> Comment on Taxation of Carried Interest – The Debate Continues as Legislation Looms by Roger http://rroyselaw.com/blog1/2010/01/07/taxation-of-carried-interest-%e2%80%93-the-debate-continues-as-legislation-looms/comment-page-1/#comment-1653 Roger Sun, 12 Jun 2011 20:26:12 +0000 http://rroyselaw.com/blog1/?p=17#comment-1653 Doug - this is more policy driven than logical. The right answer as an economic matter is that the compensatory portion should be taxed. It is just a matter of time before we get there as a legislative matter. Roger Doug – this is more policy driven than logical. The right answer as an economic matter is that the compensatory portion should be taxed. It is just a matter of time before we get there as a legislative matter.

Roger

]]> Comment on The Entertainment Industry and § 409A: That’s Hollywood! by Roger http://rroyselaw.com/blog1/2009/10/16/about/comment-page-1/#comment-1652 Roger Sun, 12 Jun 2011 20:15:44 +0000 http://phillycoolrob.com/wordpress_281/?page_id=2#comment-1652 Dear Confused, sometimes the law requires restructuring. I don't have a magic bullet for this and it is either "hide in the weeds" and take the risk (not a gerat solution with current reporting requirements) or elminate the deferred portions. We all agree that 409A is simply stupid in its reach, but a potential revenue raiser for the IRS against the uninformed. Dear Confused, sometimes the law requires restructuring. I don’t have a magic bullet for this and it is either “hide in the weeds” and take the risk (not a gerat solution with current reporting requirements) or elminate the deferred portions. We all agree that 409A is simply stupid in its reach, but a potential revenue raiser for the IRS against the uninformed.

]]> Comment on IRS Announces Second Chance for Offshore Account Holders, Deadline of August 31, 2011 by Solomon Reid http://rroyselaw.com/blog1/2011/02/13/irs-announces-second-chance-for-offshore-account-holders-deadline-of-august-31-2011/comment-page-1/#comment-1112 Solomon Reid Fri, 25 Feb 2011 18:11:06 +0000 http://rroyselaw.com/blog1/?p=52#comment-1112 What a great and informative post. It's important to consider the ramifications of this new initiative also I didn't realize that you can’t already be under investigation by the IRS or participated in the 2009 version of this program to participate in this new initiative. Thanks again for the information and here is a <a href="//www.stonecarlie.com/blog/post/2011/02/01/2011-Offshore-Voluntary-Disclosure-Initiative-%28OVDI%29.aspx”" rel="nofollow">similar OVDI blog</a> that shares similar information... figured I'd share. Thanks! What a great and informative post. It’s important to consider the ramifications of this new initiative also I didn’t realize that you can’t already be under investigation by the IRS or participated in the 2009 version of this program to participate in this new initiative. Thanks again for the information and here is a similar OVDI blog that shares similar information… figured I’d share. Thanks!

]]> Comment on The Entertainment Industry and § 409A: That’s Hollywood! by still confused http://rroyselaw.com/blog1/2009/10/16/about/comment-page-1/#comment-7 still confused Wed, 20 Jan 2010 16:43:49 +0000 http://phillycoolrob.com/wordpress_281/?page_id=2#comment-7 Are there any solutions being used -- outside of a contractual redraft or legislative workout? Are there any solutions being used — outside of a contractual redraft or legislative workout?

]]> Comment on Taxation of Carried Interest – The Debate Continues as Legislation Looms by Doug Park http://rroyselaw.com/blog1/2010/01/07/taxation-of-carried-interest-%e2%80%93-the-debate-continues-as-legislation-looms/comment-page-1/#comment-5 Doug Park Thu, 07 Jan 2010 16:31:15 +0000 http://rroyselaw.com/blog1/?p=17#comment-5 If substance over form dictates the result, then ordinary income treatment may be the more logical outcome. Where you come down Roger? If substance over form dictates the result, then ordinary income treatment may be the more logical outcome.

Where you come down Roger?

]]> Comment on Offshore Bank Account Reporting Developments by Mr WordPress http://rroyselaw.com/blog1/2009/09/21/hello-world/comment-page-1/#comment-1 Mr WordPress Tue, 29 Sep 2009 09:02:56 +0000 http://phillycoolrob.com/wordpress_281/?p=1#comment-1 Hi, this is a comment.<br />To delete a comment, just log in and view the post's comments. There you will have the option to edit or delete them. Hi, this is a comment.
To delete a comment, just log in and view the post's comments. There you will have the option to edit or delete them.

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