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In episode 59 of How Tax Works, Matt Foreman discusses allocations and distributions, and the requirement that the allocations have Substantial Economic Effect, which is broken into two parts, (i) that the allocations have economic effect and (ii) that the economic effect is substantial on a pre-tax and post-tax basis.
How Tax Works, hosted by Falcon Rappaport & Ber...
In episode 58 of How Tax Works, Matt Foreman discusses Zhang v. IRS, No. 4:24-cv-08210 (N.D. Cal. 2026), which held that the IRS does not need to file a civil lawsuit to impose penalties for a late-filed Form 3520. Zhang is a related case to Farhy, and applies the same principles to penalties for late- or non-filed Forms 3520-A, 5471, and 5472
How Ta...
In episode 57 of How Tax Works, Matt Foreman discusses New York City’s brand new Pied-a-terre tax, outlining some of its most interesting points and potential audit issues
How Tax Works, hosted by Falcon Rappaport & Berkman LLP Partner Matthew E. Foreman, Esq., LL.M., delves into the intricacies of taxation, breaking down complex concepts for a clearer understanding...
In episode 56 of How Tax Works, Matt Foreman discusses Kwong v. United States, 179 Fed. Cl. 382 (2025), specifically whether interest and penalties must be abated, plus bonus commentary about whether Kwong will be reversed on appeal.
How Tax Works, hosted by Falcon Rappaport & Berkman LLP Partner Matthew E. Foreman, Esq., LL.M., delves into the intricacies ...
In episode 55 of How Tax Works, Matt Foreman discusses S Corps (again), the viability of the GP/LP structure, the Fifth Circuit’s decision in Sirius Solutions, and the future of section 1402(a)(13) of the Internal Revenue Code.
How Tax Works, hosted by Falcon Rappaport & Berkman LLP Partner Matthew E. Foreman, Esq., LL.M., delves into the intricacies of taxation, br...