• • Wealth Preservation
  • • Employee Stock Options
  • • Foreign Taxpayers
  • • Tax & Trust Scams
  • • General Tax Information

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.

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

New
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
Articles
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
Recent Experiences with Audits of Overseas Taxpayers and Foreign Accounts (2006)
Taxation of E-Commerce
Tax-Free Money - What a Concept!
Taxpayer's Relief Act of 1997 ( 29 pages) - Selected Issues
IRA's - The Ticking Time Bomb ( 21 pages)
The 1996 Tax Reform Legislation ( 47 pages)
Accumulation Trusts After the Revenue Reconciliation Act of 1993 ( 23 pages)
Radical Tax Reform Proposals ( 20 pages)
Foreign Trusts and Gifts ( 13 pages )
Single Asset Entity and Deferred Section 1031 Exchanges ( 6 pages)
Tax Implications of Your Association's Dues ( 3 pages)
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.
Archives
To access the above files, click on Archives.