Publications

Section Newsletter Articles From Edward J. Hannon

New financial reporting rules and proposed IRS rules would raise the stakes on taking aggressive tax positions By Edward J. Hannon and Michelle B. Baxter Federal Taxation, May 2010 Two recent changes to financial reporting and tax return disclosure rules could impact whether taxpayers will choose to take tax positions that have a significant chance of being challenged by the IRS.
The Illinois Series LLC provides several planning opportunities but significant issues remain unresolved By Edward J. Hannon Federal Taxation, June 2007 In 2005, Illinois amended its Limited Liability Company Act to provide for the creation of a “Series LLC.”
Chairman’s corner By Edward J. Hannon Federal Taxation, June 2003 Members of the Federal Tax Section Council recently had the opportunity to meet with Congressman Rahm Emanuel and members of the legislative staff for Speaker of the House Dennis Hastert, Congressman John Shimkus and Congressman Jerry Weller to discuss pending tax legislation and proposed tax simplification measures
Chairman’s corner By Edward J. Hannon Federal Taxation, January 2003 On January 7, 2003, President Bush announced plans for a tax stimulus package that included a provision that would exempt dividends from federal income tax.
Chairman’s corner By Edward J. Hannon Federal Taxation, November 2002 For members of the Federal Taxation Section who have not visited the section's Web site (or perhaps more realistically, did not know it existed), the number that appears above your name on your mailing label is your password.
The Internet and personal property like-kind exchanges— The brave new world By Edward J. Hannon Federal Taxation, November 2002 Under the rules of section 1031 of the Internal Revenue Code, a taxpayer will recognize no gain for federal income tax purposes if, among other things, the taxpayer exchanges property that is used in the taxpayer's trade or business or held for investment solely for like-kind property that is used in the taxpayer's trade or business or is held for investment.
The tax treatment of tenant-in-common ownership interests in a like kind exchange is now the subject of a recently issued revenue procedure By Edward J. Hannon and Elizabeth S. Tenney Federal Taxation, June 2002 On March 20, 2002, the Internal Revenue Service (IRS) issued Revenue Procedure 2002-22, which sets forth the conditions under which the IRS will consider a request for private letter ruling on the issue of whether an undivided fractional interest in real property qualifies as qualifying replacement property for purposes of the tax-free like kind exchange rules of Code Section 1031.
The Economic Growth and Tax Relief Reconciliation Act Of 2001 provides for a tax-free method of funding college education By Edward J. Hannon, Jonathan M. Cesaretti, and Raquel Villanueva Federal Taxation, January 2002 The unique combination of tax and non-tax benefits of Qualified Tuition Plans, also known as Section 529 College Savings Plans ("Section 529 Plans"), make them one of the most important means for saving for higher education today.
Tax planning opportunities using the new 18 percent capital gain rate By Edward J. Hannon and Jonathan M. Cesaretti Federal Taxation, June 2001 The Taxpayer Relief Act of 1997 (the "1997 Act") changed the rate at which federal income tax was imposed on long-term capital gain rates. As originally enacted, the 1997 Act created three rates, a 28% rate, a 25% rate and a 20% rate
Recently enacted legislation could adversely effect partnerships that sell property in exchange for an installment obligation By Edward J. Hannon Federal Taxation, April 2000 On December 17, 1999, President Clinton signed the Ticket to Work and Work Incentive Improvement Act of 1999 (the "1999 Act") into law.
Partnerships and the new capital gain rules—new guidance from the IRS By Edward J. Hannon Federal Taxation, November 1999 In August, the IRS issued two proposed regulations that provide guidance on some of the previously unresolved issues facing partnerships and limited liability companies.
Single member limited liability companies – the new year brings new guidance from the IRS By Edward J. Hannon Federal Taxation, April 1999 In recent years, the concept of having an entity that is disregarded for federal income tax purposes has become a hot topic.

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