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A collection of the Tax Prophet's writings, ranging from client newsletters to tax articles written for the prestigious Journal of Taxation -- even a tax fairy tale!. Something for everybody!
For a list of the Tax Prophet's Speeches, click here.
Use of Revocable and Irrevocable Trusts
Revocable Living Trust vs. Will
Memo on S corporations
Introducing the Limited Liability Company
The Revenue Reconciliation Act of 1993
Read His Lips, Clinton's Tax Proposals
When the Tax Man Cometh
Investing in a Second Residence
Sale of a Principal Residence (outdated)
Newsletters - 2003
A Revocable Trust - The Basics
Comparing S corporations with Limited Liability Companies
Note: The following Basic Memos are short descriptions of typical subject-matter inquiries received via search engines when different key words are used. Memos which do not contain new material have the words "same as above."
Irrevocable Trust Memo - The Basics
Irrevocable Living Trust Memo - The Basics (same as above)
Inter Vivos Trust Memo - The Basics
Living Trust Memo - The Basics (same as above)
Revocable Living Trust Memo - The Basics (same as above)
Asset Protection - An Introduction
Domestic Asset Protection - the Basics
U. S. Asset Protection - the Basics (same as above)Using Domestic Asset Protection Trusts to Avoid Bankruptcy
Foreign Asset Protection
Off-Shore Asset Protection (same as above)
Offshore Asset Protection (same as above)
Abusive Tax Shelters
The Son of Boss Abusive Tax Shelter
Tax Consequences of Stock Option Backdating
Incentive Stock Options
Incentive Stock Options ("ISO") (same as above)
Nonqualified Stock Options
California's FTB Targets Derivium Loan TransactionsDerivium Loan Update: IRS Targets Derivium Loan Transactions
Crackdown on Executive Stock Option Tax Shelters
Non-Resident Alien Taxpayers
Non-resident Alien Taxpayers
Non-resident Alien "NRA") Taxpayers (same as above)
Your Independent Contractor Business: Choice of Entity
IRS Targets Private Annuity Trust Tax Ploy
Tax Consequences of Damages Received For Casualty Loss of Principal Residence
Trusts with Appreciated Real Estate Should Consider Using an LLC as an Investment Entity
Estate Planning and Taxation of NRA (British) Spouse
Distributions from Non-qualified Benefit Plans and California Non-residency Issues
Tax Consequences of Receipt and Exercise of Stock Options or Warrants
Sham Trust Analysis
Do You Really Owe Taxes on Your Baby-Sitter?, Tax Notes.
Like-Kind Prop. Regs Create New Safe Harbors While Adding Complexities, Journal of Taxation for Accountants.
Trading Down a Principal Residence Need Not Be Taxable, Journal of Taxation.
Deferred Like-Kind Exchanges Under Section 1031(a)(3) After Starker, Journal of Taxation.
These outlines were provided in conjunction with various speeches and lectures given by the Tax Prophet. The freely available Adobe Acrobat Reader is needed to read and print PDF files.
Recent Experiences with Audits of Overseas Taxpayers and Foreign Accounts (2006) - Strategies to consider when defending overseas taxpayers in audits involving foreign-source income and foreign bank accounts.
Taxation of E-Commerce - A discussion of the emerging tax issues associated with E-commerce. Presented to the Tax Update and planning Conference - California CPA Education Foundation, November 22 & 23, 1999.
Microsoft Word Version
Tax-Free Money - What a Concept! - An outline describing the 1997 tax changes, including the exclusion for the sale of a residence and the new Roth-IRA (aka the perpetual tax-free money machine). Presented to the Renaissance Executive Forum, November 19, 1998; Marin County Estate Planning Council, October, 1998; and San Francisco Attorney's Probate Association, May 28, 1998.
Microsoft Word Version
Taxpayer's Relief Act of 1997 ( 29 pages) - Selected Issues - Presented to Van Kasper and Company, San Francisco, CA, September 23, 1997
Highlights of the1997 law and a discussion of selected issues.
Microsoft Word Version (36K)
IRA's - The Ticking Time Bomb ( 21 pages) - Present to The New Chase Trust Co. and Butterfield & Butterfield, San Francisco, CA, October 30, 1996
Estate planning opportunities and pitfalls involving IRAs.
Microsoft Word Version (89K)
The 1996 Tax Reform Legislation ( 47 pages) - Presented to CPA/Law Forum, San Francisco, CA, November 21, 1996.
A discussion of selected issues presented by the 1996 Tax Act.
Microsoft Word Version (170K)
Accumulation Trusts After the Revenue Reconciliation Act of 1993 ( 23 pages) - Presented to the Chemical Trust Company, November 14, 1995 for MCLE credit and to the CPA/Law Forum, San Francisco, January 20, 1994.
Creative methods for using trusts to accumulate income even though the RRA 93 created a 39.6% tax bracket for trust income in excess of $7,500.
Microsoft Word Version (122K)
Radical Tax Reform Proposals ( 20 pages) - Presented to CPA/Law Forum, San Francisco, CA, CPA/Law Forum, October 26, 1995 and the State Bar o California, Tax Section on December, 19, 1995, Mandatory Continuing Legal Education (MCLE) and Legal Specialization credit.
A discussion of the Flat Tax, National Sales Tax and other proposals for radically altering the present tax system. The Tax Prophet concludes that these proposals will not work and are merely political gimmicks intended to take advantage of the electorate's anger and frustration at the present system.
Microsoft Word Version (102K)
Foreign Trusts and Gifts ( 13 pages ) - Presented to the California Society of Enrolled Agents, Golden Gate Chapter, September 4, 1997.
The tax changes regarding in-bound and out-bound foreign trusts and their reporting requirements. Also, a presentation on the new gift reporting requirements imposed on U.S. taxpayers receiving foreign gifts.
PDF Version (43K)
Microsoft Word Version (72K)
Single Asset Entity and Deferred Section 1031 Exchanges ( 6 pages) - Presented to a real estate investment firm in 1993.
A discussion of how to combine the creation of a single-asset entity with a Section 1031 exchange without running afoul of the IRS's opposition to these transactions.
Microsoft Word Version (25K)
Tax Implications of Your Association's Dues ( 3 pages) - Presented to Executives Association Southwestern Regional Conference, March 25, 1995.
Under what circumstances are dues paid to business leagues and organizations deductible?
Microsoft Word Version (18K)
Limited Liability Companies ( 7 pages) - Presented to the Northern California Trust Companies Association, March 21, 1995. Update to the law was presented to the Northern California Trust Companies Association, May 9, 2000. Note: The outline was updated to reflect 1999 law changes.
California's Limited Liability Company Act. When should you use an LLC?
Microsoft Word Version
The Slaying of the Tax Dragon
A fairytale involving a poor taxpayer who failed to pay his employment taxes, an evil tax dragon lying in wait and a mystical tax wizard saves the day (of course) with an ingenious approach! An invaluable lesson for those who might forget to pay their payroll taxes.
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[Wealth Preservation] [Employee Stock Options] [Foreign Taxpayers] [Tax & Trust Scams] [Expert Witness] [General Tax Information] All contents copyright ? 2008 Robert L. Sommers, attorney-at-law. All rights reserved. This internet site provides information of a general nature for educational purposes only and is not intended to be legal or tax advice. This information has not been updated to reflect subsequent changes in the law, if any. Your particular facts and circumstances, and changes in the law, must be considered when applying U.S. tax law. You should always consult with a competent tax professional licensed in your state with respect to your particular situation. The Tax Prophet(TM) is a trademark of Robert L. Sommers.