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!
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."
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 
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.
PDF Version
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.
PDF Version
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.
PDF Version
(33K)
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.
PDF Version
(67K)
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.
PDF Version
(142K)
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.
PDF Version
(66K)
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.
PDF Version
(63K)
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.
PDF Version
(20K)
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?
PDF Version
(9K)
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?
PDF Version
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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