GCK On Law
Last Chance for Those with Foreign Accounts or Assets to Participate in IRS Offshore Voluntary Disclosure Program (OVDP)
Since 2009, the IRS has permitted taxpayers with undisclosed bank, investment, or retirement accounts outside the U.S., or any other foreign asset (real estate, stock or partnership interest, life insurance, etc.), to voluntarily come forward and disclose their...
Valuation Considerations in proposing Dirt-for-Debt plans of reorganization
Section 1129 of the Bankruptcy Code governs confirmation of a Chapter 11 plan. Section 1129(b) of the Bankruptcy Code allows for confirmation of a plan over a creditor’s objection as long as certain requirements are met. One such requirement for cramdown is that the...
Employee or Independent Contractor? Employers DON’T get to decide!
Small and large businesses alike often classify certain workers as independent contractors rather than employees. Sometimes the belief that the workers are contractors is genuine, because of the type of work or industry practice. Other times, businesses classify...
Treatment of nonresidential real property within the Bankruptcy Code
Under the Bankruptcy Code, non-residential real estate gets special treatment. Pursuant to Sections 362(b)(10), 365(c)(3), 365(d)(4)(A) and 541(b)(2) of the Bankruptcy Code, if real estate is deemed “nonresidential” in nature, a lease of such property terminated...
Gasp! An IRS Letter Arrived! What Should I Do?
Given the complexity of the U.S. tax system, it is not surprising that most taxpayers fear IRS on some level. Many of our clients are often overwhelmed by the idea of having to deal with a tax issue, no matter how simple. If you happen to receive a letter or notice...