David Sherwood David Sherwood

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David D. Sherwood focuses his practice on a broad range of domestic tax issues affecting corporations, joint ventures and their owners, including the tax treatment of spin-offs and other restructurings, consolidated returns, the availability of deductions on the worthlessness or other disposition of stock, and the formation of investment partnerships, real estate partnerships, corporate joint ventures and multinational group internal partnerships. Read David Sherwood's full bio.

CARES Act Update: IRS Provides Guidance to Partnerships to Take Advantage of Liquidity Benefits


By , , , and on Apr 13, 2020
Posted In IRS Guidance, Tax Refunds, Uncategorized

On April 8, 2020, the Internal Revenue Service (IRS) issued Rev. Proc. 2020-23 in response to the Coronavirus Aid, Relief and Economic Security (CARES) Act. Rev. Proc. 2020-23 eases restrictions on partnerships’ ability to file amended tax returns and issue amended Schedules K-1 in order for their partners to avail themselves of the retroactive tax relief provided...

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Tax Reform Insights: IRS Proposes Section 163(j) Regulations – New Business Interest Expenses Deduction Limit


By , , and on Dec 26, 2018
Posted In IRS Guidance, Tax Reform, Uncategorized

On November 26, 2018, the Internal Revenue Service (IRS) issued proposed regulations (Proposed Regulations) pursuant to section 163(j). Public Law 115-97, the Tax Cuts and Jobs Act (TCJA), amended Internal Revenue Code (Code) Section 163 by modifying paragraph (j) to limit the amount of business interest a taxpayer may deduct for taxable years beginning after...

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Sixth Circuit Sets Limits on the Application of the Substance-Over-Form Doctrine


By and on Feb 21, 2017
Posted In Appellate Courts, Uncategorized

The judicial substance-over-form doctrine provides the IRS with the ability to set aside carefully orchestrated tax planning arrangements to treat a transaction consistent with its substance.  However, the doctrine does not give the Service carte blanche to deny tax benefits. In Summa Holdings, Inc. v. Commissioner, No. 16-1712 (available here), the Sixth Circuit overturned the...

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