Newsletters, Articles and Outlines

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.

Newsletters - old

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

Nannygate Revisited

Read His Lips, Clinton's Tax Proposals

When the Tax Man Cometh

Investing in a Second Residence

Sale of a Principal Residence (outdated)

Estate Planning

Newsletters - 2003

A Revocable Trust - The Basics

Tax Problems

Basic Memos

Entity Planning

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."

Trust Memos

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

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

Stock Options

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 Transactions

Derivium 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)

Detailed Memos

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.

   Tax Outlines  

These outlines were provided in conjunction with various speeches and lectures given by the Tax Prophet. The freely available Adobe Acrobat Reader   pdficon.gif (224 bytes) 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.

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  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.

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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.

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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.

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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.

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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.

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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.

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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.

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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. 

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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?

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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?

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Tax Tales

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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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.