Assume that X and Y agree to the following: X will transfer ownership of Prop to Y, and Y will transfer cash to X. What just happened? Obviously, X has sold Prop to Y. If the.
Heads I Win, . . . - When closely held corporations that are under common control engage in any intercompany transaction, it is prudent for the corporations and their.
In Clark Raymond & Co., PLLC v. Commissioner, the US Tax Court upheld a partnership’s distributions of "client-based intangible assets" (i.e., books…