In episode 47 of How Tax Works, Matt Foreman continues his discussion of substance versus form issues, focusing on the Step Transaction Doctrine, discussing the three tests and how they’re used and misused. 

How Tax Works, hosted by Falcon Rappaport & Berkman LLP Partner Matthew E. Foreman, Esq., LL.M., delves into the intricacies of taxation, breaking down complex concepts for a clearer understanding of how tax laws impact your financial decisions.

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This podcast may be considered attorney advertising. This podcast is not presented for purposes of legal advice or for providing a legal opinion. Before any of the presenting attorneys can provide legal advice to any person or entity, and before an attorney-client relationship is formed, that attorney must have a signed fee agreement with a client setting forth the firm’s scope of representation and the fees that will be charged.

This Podcast is Hosted by:
Falcon Rappaport & Berkman LLP
1185 Avenue of the Americas, Suite 1415
New York, NY 10036
(212) 203 -3255
[email protected]

In episode 46 of How Tax Works, Matt Foreman begins his discussion of substance versus form issues, beginning with the Economic Substance Doctrine, from its beginnings in case law to its codification in I.R.C. ? 7701(o).

How Tax Works, hosted by Falcon Rappaport & Berkman LLP Partner Matthew E. Foreman, Esq., LL.M., delves into the intricacies of taxation, breaking down complex concepts for a clearer understanding of how tax laws impact your financial decisions.

Follow us on Bluesky:
@howtaxworks.bsky.social

This podcast may be considered attorney advertising. This podcast is not presented for purposes of legal advice or for providing a legal opinion. Before any of the presenting attorneys can provide legal advice to any person or entity, and before an attorney-client relationship is formed, that attorney must have a signed fee agreement with a client setting forth the firm’s scope of representation and the fees that will be charged.

This Podcast is Hosted by:
Falcon Rappaport & Berkman LLP
1185 Avenue of the Americas, Suite 1415
New York, NY 10036
(212) 203 -3255
[email protected]

In episode 45 of How Tax Works, Matt Foreman discusses how to have stock sales taxed as asset sales by using F Reorganizations, selling wholly-owned subsidiaries, and elections under 336(e) and 338(h)(10). 

How Tax Works, hosted by Falcon Rappaport & Berkman LLP Partner Matthew E. Foreman, Esq., LL.M., delves into the intricacies of taxation, breaking down complex concepts for a clearer understanding of how tax laws impact your financial decisions.

Follow us on Bluesky:
@howtaxworks.bsky.social

This podcast may be considered attorney advertising. This podcast is not presented for purposes of legal advice or for providing a legal opinion. Before any of the presenting attorneys can provide legal advice to any person or entity, and before an attorney-client relationship is formed, that attorney must have a signed fee agreement with a client setting forth the firm’s scope of representation and the fees that will be charged.

This Podcast is Hosted by:
Falcon Rappaport & Berkman LLP
1185 Avenue of the Americas, Suite 1415
New York, NY 10036
(212) 203 -3255
[email protected]

In episode 44 of How Tax Works, Matt Foreman discusses common mistakes, misconceptions, and missteps involving qualified small business stock (QSBS) under section 1202, including exclusion stacking, state issues, the use of partnerships, and other common problems.

How Tax Works, hosted by Falcon Rappaport & Berkman LLP Partner Matthew E. Foreman, Esq., LL.M., delves into the intricacies of taxation, breaking down complex concepts for a clearer understanding of how tax laws impact your financial decisions.

Follow us on Bluesky:
@howtaxworks.bsky.social

This podcast may be considered attorney advertising. This podcast is not presented for purposes of legal advice or for providing a legal opinion. Before any of the presenting attorneys can provide legal advice to any person or entity, and before an attorney-client relationship is formed, that attorney must have a signed fee agreement with a client setting forth the firm’s scope of representation and the fees that will be charged.

This Podcast is Hosted by:
Falcon Rappaport & Berkman LLP
1185 Avenue of the Americas, Suite 1415
New York, NY 10036
(212) 203 -3255
[email protected]

In episode 43 of How Tax Works, Matt Foreman discusses the three allowable methods Traditional, Traditional with Curative Allocations, and Remedial; the Ceiling Rule problem and how each method creates or mitigates the Ceiling Rule problem; and whether Other Reasonable Methods are really a viable option.

How Tax Works, hosted by Falcon Rappaport & Berkman LLP Partner Matthew E. Foreman, Esq., LL.M., delves into the intricacies of taxation, breaking down complex concepts for a clearer understanding of how tax laws impact your financial decisions.

Follow us on Bluesky:
@howtaxworks.bsky.social

This podcast may be considered attorney advertising. This podcast is not presented for purposes of legal advice or for providing a legal opinion. Before any of the presenting attorneys can provide legal advice to any person or entity, and before an attorney-client relationship is formed, that attorney must have a signed fee agreement with a client setting forth the firm’s scope of representation and the fees that will be charged.

This Podcast is Hosted by:
Falcon Rappaport & Berkman LLP
1185 Avenue of the Americas, Suite 1415
New York, NY 10036
(212) 203 -3255
[email protected]

In episode 42 of How Tax Works, Matt Foreman discusses the often misunderstood Offer in Compromise process, focusing on what types of OICs are likely to get accepted and the different reasons to request one, as well as state OIC corollaries.

How Tax Works, hosted by Falcon Rappaport & Berkman LLP Partner Matthew E. Foreman, Esq., LL.M., delves into the intricacies of taxation, breaking down complex concepts for a clearer understanding of how tax laws impact your financial decisions.

Follow us on Bluesky:
@howtaxworks.bsky.social

This podcast may be considered attorney advertising. This podcast is not presented for purposes of legal advice or for providing a legal opinion. Before any of the presenting attorneys can provide legal advice to any person or entity, and before an attorney-client relationship is formed, that attorney must have a signed fee agreement with a client setting forth the firm’s scope of representation and the fees that will be charged.

This Podcast is Hosted by:
Falcon Rappaport & Berkman LLP
1185 Avenue of the Americas, Suite 1415
New York, NY 10036
(212) 203 -3255
[email protected]

In episode 41 of How Tax Works, Matt Foreman gives an overview of what taxpayers and their advisors should do and expect when they owe money and want to pay it off over time, while trying to lower the amount due without continuing the auditor or litigation.

How Tax Works, hosted by Falcon Rappaport & Berkman LLP Partner Matthew E. Foreman, Esq., LL.M., delves into the intricacies of taxation, breaking down complex concepts for a clearer understanding of how tax laws impact your financial decisions.

Follow us on Bluesky:
@howtaxworks.bsky.social

This podcast may be considered attorney advertising. This podcast is not presented for purposes of legal advice or for providing a legal opinion. Before any of the presenting attorneys can provide legal advice to any person or entity, and before an attorney-client relationship is formed, that attorney must have a signed fee agreement with a client setting forth the firm’s scope of representation and the fees that will be charged.

This Podcast is Hosted by:
Falcon Rappaport & Berkman LLP
1185 Avenue of the Americas, Suite 1415
New York, NY 10036
(212) 203 -3255
[email protected]

In episode 40 of How Tax Works, Matt Foreman continues his discussion of tax controversy, discussing appeals and litigation, focusing on timing, audit risk, and other related issues.

How Tax Works, hosted by Falcon Rappaport & Berkman LLP Partner Matthew E. Foreman, Esq., LL.M., delves into the intricacies of taxation, breaking down complex concepts for a clearer understanding of how tax laws impact your financial decisions.

Follow us on Bluesky:
@howtaxworks.bsky.social

This podcast may be considered attorney advertising. This podcast is not presented for purposes of legal advice or for providing a legal opinion. Before any of the presenting attorneys can provide legal advice to any person or entity, and before an attorney-client relationship is formed, that attorney must have a signed fee agreement with a client setting forth the firm’s scope of representation and the fees that will be charged.

This Podcast is Hosted by:
Falcon Rappaport & Berkman LLP
1185 Avenue of the Americas, Suite 1415
New York, NY 10036
(212) 203 -3255
[email protected]

In episode 39 of How Tax Works, Matt Foreman discusses what you should do if you get audited, including discussing the process of an audit, how to politely push back, and why you should never, ever ignore the audit.

How Tax Works, hosted by Falcon Rappaport & Berkman LLP Partner Matthew E. Foreman, Esq., LL.M., delves into the intricacies of taxation, breaking down complex concepts for a clearer understanding of how tax laws impact your financial decisions.

Follow us on Bluesky:
@howtaxworks.bsky.social

This podcast may be considered attorney advertising. This podcast is not presented for purposes of legal advice or for providing a legal opinion. Before any of the presenting attorneys can provide legal advice to any person or entity, and before an attorney-client relationship is formed, that attorney must have a signed fee agreement with a client setting forth the firm’s scope of representation and the fees that will be charged.

This Podcast is Hosted by:
Falcon Rappaport & Berkman LLP
1185 Avenue of the Americas, Suite 1415
New York, NY 10036
(212) 203 -3255
[email protected]

In episode 38 of How Tax Works, Matt Foreman discusses the updates and modifications to Qualified Small Business Stock (IRC 1202) and R&E Expensing (IRC 174) Under OBBBA, plus a bonus discussion of how he thinks OBBBA should be pronounced.

How Tax Works, hosted by Falcon Rappaport & Berkman LLP Partner Matthew E. Foreman, Esq., LL.M., delves into the intricacies of taxation, breaking down complex concepts for a clearer understanding of how tax laws impact your financial decisions.

Follow us on Bluesky:
@howtaxworks.bsky.social

This podcast may be considered attorney advertising. This podcast is not presented for purposes of legal advice or for providing a legal opinion. Before any of the presenting attorneys can provide legal advice to any person or entity, and before an attorney-client relationship is formed, that attorney must have a signed fee agreement with a client setting forth the firm’s scope of representation and the fees that will be charged.

This Podcast is Hosted by:
Falcon Rappaport & Berkman LLP
1185 Avenue of the Americas, Suite 1415
New York, NY 10036
(212) 203 -3255
[email protected]