Personal Service Corporation Flat Tax Rate Not Applicable to Consolidated Group Income
Under Internal Code Section 11(b)(2) the taxable income of a qualified professional service corporation is taxed at the flat tax rate of 35%. The graduated rates of Internal Code Section 11(b)(1) do not apply. In Applied Research Associates, Inc. et al. v. Commissioner, the Tax Court held that the graduated tax rates…
Back-to-Back Loans Under Federal Regs
Background Corporate losses and deductions that can pass-through and be deducted by a shareholder are limited by I.R.C. §1366(d)(1). This limit is the shareholder’s total adjusted basis in the corporation’s stock and debt. If a shareholder’s share of losses and deductions exceeds such basis, the excess losses are suspended and…
2014 SuperLawyers
Six attorneys at Kulzer & DiPadova were recognized by New Jersey *Super Lawyers magazine for 2014. Kulzer & DiPadova attorneys recognized as New Jersey Super Lawyers for 2014. Arthur A. DiPadova and Glenn A. Henkel were named in the area of Estate Planning & Probate Michael A. Kulzer in the area of Closely Held Business,…
Revised Streamlined Program Offers Resident Taxpayers Options Regarding Foreign Assets
On June 18, 2014, the Internal Revenue Service announced revisions to the Streamlined Domestic Offshore Procedures (the “Streamlined Program”). The revised Streamlined Program offers reduced penalties for certain taxpayers with offshore reporting issues as compared to the higher penalties imposed under the Offshore Voluntary Disclosure Initiative (the “OVDI Program”). The Streamlined Program,…
Attorney Eric A. Feldhake Successfully Represents Client Before Pennsylvania Appellate Court
Toll Naval Assoc. v. Chun-Fang Hsu, PICS Case No. 14-0214 (Pa. Super. Jan. 30, 2014) Bender, J. (15 pages.) Eric A. Feldhake of Kulzer & DiPadova, P.A. appeared before the Pennsylvania Appellate Court representing Chun-Fang Hsu. Fox Rothchild represented Appellant Toll Naval Assoc. which appealed from the judgment entered against it confirming…
Attorney Glenn A. Henkel Appointed to Board of Philadelphia Estate Planning Council
Shareholder, Glenn A. Henkel, Esquire, was recently appointed to the Board of the Philadelphia Estate Planning Council. The Council is a “highly recognized interdisciplinary organization for professionals involved in estate planning, providing its members with opportunities to enhance their skills and expand their network through programs and interaction.” Mr. Henkel is admitted to practice before the…
Attorney Joseph M. Kempter Installed as President of SJ Chapter of Society of Financial Service Professionals
Shareholder, Joseph M. Kempter, Esquire, was recently installed as the President of the South Jersey Chapter of the Society of Financial Service Professionals. “To be accepted for regular membership in the Society, an individual must have achieved and demonstrated a high level of achievement in his or her professional career. Among other requirements, he…
Attorney Daniel L. Mellor Appointed as YLD Executive Committee Representative for Burlington County
Associate, Daniel L. Mellor, Esquire, was recently appointed as a Young Lawyers Division Executive Committee Representative for Burlington County. The Division is for “attorneys who are younger than 36 or have practiced for less than ten years, the Young Lawyers Division provides New Jersey’s newest lawyers with an opportunity to network and to enhance their…
Joseph M. Kempter, Esq. to Speak at Pennsylvania Bar Institute Seminar
Shareholder, Joseph M. Kempter will be speaking on NJ Estate Planning Issuesat “What PA Lawyers Need to Know About NJ Estate Practice”, a seminar presented by the Pennsylvania Bar Institute. The seminar will take place on Tuesday, August 19, 2014, at the CLE Conference Center, located at the Wanamaker Building, 10th Floor Suite 1010, 100…
Powers of Attorney & IRS FBAR Reference Guide
FBAR Filing and Powers of Attorney: The recently published “IRS Reference Guide on the Report of Foreign Bank and Financial Accounts (FBAR)” explains the purpose of the FBAR, who must file, and provides a host of definitions relating to the FBAR regulations. Perhaps most notably, the reference guide explains that…