Daily Tax Report Publishes Article by David Burton and Richard Page on "Disguised Sales"

Akin Gump tax partner David Burton and associate Richard Page have written the article “Tax Court Finds Partnership Formed to Share State Credits Constituted a Taxable ‘Disguised Sale,’” which was published by Bloomberg BNA’s Daily Tax Report.

The article looks at a decision by the Tax Court in SWF Real Estate, LLC v. Commissioner finding that “a purported allocation of state tax credits to a partner was actually a sale of the state tax credits to the partner.” Burton and Page offer steps taxpayers can take to reduce the risk of having their transactions recharacterized as disguised sales.

To read the full article, please click here.