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Jared R. Callister

California Tax Review

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Are Trump's HUUUGE Losses Real?

If there was something I never saw coming, it was the hand-wringing and TV pundit analys of the relatively common use of Net Operating Losses--albeit by Donald Trump.  To all tax attorneys, the very idea of rolling forward Net Operating Losses (or NOLs) is common and rather mundane.  So when I saw and heard the media headlines lambasting Mr. Trump for his use of this mega NOLs I wasn't all that surprised.  The only think that surprised me however, was the sheer size of Mr.

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Hillary Clinton Proposes 65% Estate Tax

Hillary Clinton took Senator Bernie Sanders' lead by proposing a change to the estate tax rules that would add three new tax bracket on the largest estates.  Under her proposal, a 50% rate would apply at estates over $10 million per person, a 55% rate on estates over $50 million per person, and a top rate of 65% imposed on estates exceeding $500 million per person.  Admittedly, this increase will affect a tiny number of Americans.

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IRS Proposes New Regs To Limit FLP Discounts

On August 4, 2016, the IRS issued proposed regulations that would greatly reduce estate and gift tax valuation discounts that estate planners have used for years to reduce the value of family-owned businesses for estate and gift tax purposes.   In particular, the proposed regulations further interpret Section 2704, which generally deals with voting or liquidation rights of minority owners tha

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So How Long Can the IRS Collect From Me?

One of the most frequent questions I am posed by clients is how long the IRS has to engage in collection activities.  Most clients are aware of the "10-year rule" but other than its name, have little to no knowledge as to how it actually works or how the collection statute relates to the IRS's ability to impose liens.

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