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Personal residences now offer more tax shelter

Article Abstract:

Personal residences have long been used as a low-risk investment by taxpayers since they often generate a profitable after-tax return. Regulations issued in 1997 have made these investments even more attractive, particularly for leveraged taxpayers. After-tax returns, however, are not as attractive if these residences are expensive enough to require large loans since interest rates on such high-end houses are higher, and because interest deductions are capped at the first million of debt. Guidelines are provided for tax advisors who are planning housing investments for clients.

Housing, Tax consultants, Practice, Real estate, Tax reform, Dwellings, Real property, Tax shelters

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Debt can puncture the dividends-received deduction

Article Abstract:

Issues are explored regarding the application of IRC section 246A which denies corporations the section 243 dividends-paid deduction in cases where portfolio stock is debt financed, with a focus on issues concerning affiliated corporations. Discussion of the U.S. 8th Circuit Court of Appeals case H Enterprises International is included.

Public Finance Activities, Corporate Tax Deductions & Exemptions, Corporate taxes, Debt financing (Corporations), Debt financing, Corporate distributions

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Mitigation offers escape from expired limitations period

Article Abstract:

The author discusses the qualifications necessary for double disallowance of deductions or inclusions of income to gain mitigation relief from closed limitation periods.

Limitation of actions (Taxation), Statute of limitations (Taxation)

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