🚨Episode 41🚨 Payment Plans and Penalty Abatement frblaw.com/podcast/paym...

Now Episode 40 What You Should Do If Your Audit Goes Poorly and You Need to Litigate? frblaw.com/podcast/what...

Two weeks late, but Episode 39: Episode 39 What Should You Do If You Get Audited by the IRS (or State Revenue Agency)? frblaw.com/podcast/what...

Episode 38: Updates to Qualified Small Business Stock (IRC 1202) and R&E Expensing Under OBBBA (IRC 174 and new 174A). Also, I discuss how OBBBA should be pronounced (real answer, no gimmicks): frblaw.com/podcast/upda...

Next two episodes are outlines and will be recorded next week. Tax audits & litigation.

Episode 37: If You Win the Lottery, the First Thing You Should Do Is… Call a Tax Lawyer? frblaw.com/podcast/if-y...

Episode 36: Grouping and Separate Activities Under 469 of the IRC Listen here: frblaw.com/podcast/grou... Spotify open.spotify.com/episode/4Bzh... Apple Podcasts: podcasts.apple.com/us/podcast/g... Amazon Podcasts: music.amazon.com/podcasts/968... BuzzSprout: www.buzzsprout.com/admin/237225...

Episode 35: The Installment Method Under Section 453 (and 453A!) of the IRC frblaw.com/podcast/the-...

Episodes 33 and 34: Can AI Replace Tax Lawyers? Part I: frblaw.com/podcast/can-... Part II: frblaw.com/podcast/can-...

Episode 32: NFL is exchanging NFL Network (and Red Zone!) for a 10% equity stake in ESPN. How could that work from a tax perspective? frblaw.com/podcast/how-...

I’m ready to record the next few episodes, including a two-parter on how well (or poorly) AI does with tax law.

Real Estate Investors and the Passive Activity Loss Rules under IRC 469: Listen here: frblaw.com/podcast/real...

Legit excited for the episode that’s coming out on Monday. A deep dive on IRC 469 (passive activity loss limitations) for real estate.

Episode 30: Gambling losses, whether something is a gift (or taxable income!), whether an asset is inventory or a capital asset, and closing with a discussion of Broadway producer George M. Cohan’s contribution to tax law. frblaw.com/podcast/famo...

Episode 29: Tax cases you should know! Gregory (whether there is a patriotic duty to increase one's taxes); Eisner v. Macomber (stock dividends); Danielson (substance v form); Arrowsmith (ordinary v capital, not the band); and Orrisch (subK capital accounts): frblaw.com/podcast/famo...

Recorded along with 31, which discusses

It’s go time

Episode 28: Family Offices (which doesn't require a family at all!): frblaw.com/podcast/fami...

Episodes 29 and 30 are ready to be recorded. What will I discuss? Oh, it’s gonna be goooooood.

Episode 28 out on Monday: Family Offices

Episode 27: F Reorgs Part Deux: Listen here: frblaw.com/podcast/f-re... Spotify: open.spotify.com/episode/0J1a... Apple Podcasts: podcasts.apple.com/us/podcast/f... Amazon Music: music.amazon.com/podcasts/968...

Episode 26: Now I know my ABCs next time won't you undertake an acquisitive reorganization with me? Here: frblaw.com/podcast/abcs... Also Spotify: open.spotify.com/episode/7uw7... Apple Podcasts: podcasts.apple.com/us/podcast/a... Amazon Music: music.amazon.com/podcasts/968...

Episode 25: Partnership Divisions, or I used to love you but now I hate you: frblaw.com/podcast/part... Also: Spotify: open.spotify.com/episode/1x8J... Apple Podcasts: podcasts.apple.com/us/podcast/p... Amazon Music: music.amazon.com/podcasts/968...

Episode 25 (partnership divisions) is done and will be released on Monday. Episode 26 (A B C Reorgs) is outlined and will be recorded on Tuesday. About to start outlining Episode 27, which is about (look at the picture)

Episode 24: Divisive Reorganizations (368(a)(1)(F) and 355): frblaw.com/podcast/divi... Spotify: open.spotify.com/episode/53yU... Apple Podcasts: podcasts.apple.com/us/podcast/d... Amazon Music: music.amazon.com/podcasts/968...

Episode 23: WHAT THE F IS A F REORG!?!??? frblaw.com/podcast/what...

Recording tomorrow: WHAT THE F IS A F REORG

The last vestige of Enron is the tax (and loss of business deduction!) on "excess parachute payments", or as they're more commonly known, Golden Parachutes. Episode 22 here: frblaw.com/podcast/gold...

Should foreign persons own US LLCs? Probably not. Episode 21 here: frblaw.com/podcast/why-... Also Spotify: open.spotify.com/show/59mZSlM... Apple Music: podcasts.apple.com/us/podcast/w... Amazon Podcasts: open.spotify.com/show/59mZSlM...

When your firm’s marketing group keeps it 💯 🔥🔥🔥 (they’re 1.5” squares)

Most likely the next few episodes: 23: What the F is a F Reorg 24: D Reorgs 25: Partnership Divisions 26: The ABCs of A, B, and C Reorganizations 27: Entity Selection Redux: Using a F Reorg to Mitigate an Unfortunate S Election

Recorded! March 17 (what a day to release it for many reasons) and March 31!!!

Next two episodes are going to be recorded tomorrow night!!!!! 21: Why Foreign Persons Should Not Own LLCs 22: Golden Parachutes (Yes, I make outlines by hand. They are 6 & 8 pages. A typical episode is 4-7.)

Episode 20: Why, for tax reasons, you should buy a professional sports team: frblaw.com/podcast/why-... Also via Spotify: open.spotify.com/episode/1w8W... Via Apple Podcasts: podcasts.apple.com/us/podcast/w... Via Amazon Music: music.amazon.com/podcasts/968...

Monday Monday Monday

Next few episodes: 20: Why you should buy a professional sports team [recorded] 21: Why foreign persons should (probably) not own LLCs [prepared, recording next week] 22: Golden Parachutes [half prepared, recording next week] 23: 🤷‍♂️🤷‍♂️🤷‍♂️

Episode 19: Qualified Small Business Stock (IRC 1202) part 3: stacking exclusions, MFJ gets one or two exclusions (I think two), and rollover if you don't make it the full five years: frblaw.com/podcast/qual...

While on a plane, I prepared for episode 21: Why foreign persons shouldn’t own LLCs, which is going to be somewhere between deep technical knowledge and complaining about crappy tax advisors who don’t know what they don’t know.

Qualified Small Business Stock (Part II): Original Issuance requirement, redemptions, gifts, partnership distributions, short positions, the Qualified Small Business requirement, the Active Business requirement, possible meanings of “substantially all”, and what types of business qualify.

Qualified Small Business Stock (Part I): frblaw.com/podcast/qual...

People ask me questions about weddings: frblaw.com/podcast/ques...

Tax Issues with Divorce frblaw.com/podcast/tax-...

Loss Limitations: Episode 14 on At-risk Limitations (IRC 465): frblaw.com/podcast/at-r... and Episode 13 on Passive Activity Loss Limitations (IRC 469): frblaw.com/podcast/pass...

Self-employment Tax on Partners, Net Investment Income Tax, and Soroban Capital Partners LP v. Comm’r (Part I) frblaw.com/podcast/self... and (Part II) frblaw.com/podcast/self...

Tax Consequences of Forming, Selling, and Dissolving Partnerships and Disregarded Entities (Rev. Rul. 99-5 and Rev. Rul. 99-6) frblaw.com/podcast/tax-...

Various State and Local Income Tax Issues (all of which are super interesting) frblaw.com/podcast/vari...

Convertible Debt and SAFEs: frblaw.com/podcast/conv...

Equity Compensation and 83(b) elections: frblaw.com/podcast/equi... Profits Interests, Promotes, and How to Structure Equity-based Compensation frblaw.com/podcast/prof...

Ordinary and Necessary Business Expenses (Part I): frblaw.com/podcast/ordi... and (Part II): frblaw.com/podcast/ordi...

How Tax Works Episode 3: Residency for income tax purposes frblaw.com/podcast/resi...