One of the basic principles of tax law is the economic substance doctrine. As recognized for many years in case law, under the economic substance doctrine, courts would generally examine both whether a transaction had economic substance beyond tax
In traditional Chinese medicine, the main function of the kidneys is to store essence. The marrow in the bones is generated from the essence in the kidneys. As long as there is sufficient essence available, the marrow is able to act. The marrow is
Among the many tools available for persons seeking asset protection is the “domestic asset protection trust” (the “DAPT”). Broadly speaking, DAPTs are U.S. domestic trusts established by a grantor, who generally retains certain rights over
Holy Bible and ancient Chinese Medicine texts teach us this same fact: the breath of God enters the nose. And for proper nourishment, air must pass thru the nose and into the lungs without friction. Changes made to the face or body, improper diet and
Given that asset values tend to increase over time, and Federal estate tax liability tends to arise more on the death of a “second-to die” spouse than on the death of a “first-to-die” spouse, portability can be a critical concept to minimize
The Apostle Paul wrote openly in the New Testament on the lust of the flesh and earthly desires; versus the fruit of the Spirit. And how selfish carnal cravings are contrary to the Spirit. Interestingly, ancient Chinese Medicine texts reveal a similar
One key change for business taxpayers under the 2025 Tax Act concerns the tax treatment of “domestic research or experimental expenditures” (often also referred to as “U.S. R&D” costs). Also, the 2025 Tax Act permanently enacts into law
Whether it is called by its popular name, the “One Big Beautiful Bill Act”, or by its official legal name, “An Act . . . To provide for reconciliation pursuant to title II of H. Con. Res. 14”, the legislation enacted by Congress on July 3,
This article focuses on “related party” transactions under Internal Revenue Code Section 267(a)(1) and Internal Revenue Code Section 1239(a). While there is some overlap, it should be noted that the specific scope of “related parties” for purposes
A less well-known rule that can affect the tax deduction of losses from the sale of stock is the wash sale rule, enacted under Internal Revenue Code Section 1091. This article discusses the application of the wash sale rule.
It has been stated that the limited liability company has become more popular than the corporation as the basic form of entity to do business in the United States. A critical document with any limited liability company is the operating agreement. When
President Trump announced a new immigration proposal – what he referred to as a “gold card”. The “gold card” green card program would potentially replace the existing EB-5 immigration program. Although it has been reported that the Trump