Explore the comprehensive rules for attributing stock ownership and defining related parties, including family and entity constructive ownership per the Internal Revenue Code.
Explore how special IRS rules disallow losses and may defer gains in related-party transactions, preventing taxpayers from recognizing or deducting artificial losses and manipulating tax outcomes.
Explore comprehensive rules for imputed interest under IRC Section 7872, focusing on gift loans, corporate-shareholder loans, and how to calculate and report below-market interest.
Explore how family partnerships and complex structures present unique opportunities and challenges in tax planning, including property shifting, disguised gifts, and special allocations.