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Sunday, August 12, 2007. USING RETROACTIVE EFFECTIVE DATES IN AGREEMENTS. Tax effects flow from the date transactions occur. For example, in a recent Tax Court case, a dispute arose in regard to a change in ownership of interests in a limited liability company (LLC). In the end, the IRS position was upheld. It is interesting that this is the opposite of what you would expect normally it is the taxpayer that wants to use the prior effective date and the IRS seeking to ignore it. The case was instructive of several principles that apply to retroactive effective dates. These include: For LLC's taxable as a partnership, the members are of the LLC are taxable directly on their percentage share of the income and losses of the LLC. Therefore, a transfer of an interest will result in changes to the shares of income (or loss) to be allocated to the involved members, effective as of the date of transfer. -The Tax Court will be more willing to accept a retroactive effective date if it can be shown that the later written documents is merely a memorialization of a prior oral agreement. Therefore, if this is the case, it would probably be helpful to recite this in the documentation. LINKS AND RESOURCES. 1 Gutter Chaves Josepher Rubin Forman Fleisher Miller P.A. 2 Professional Resume of Charles Rubin. 3 Rubin on Probate Litigation. 4 Federal & Florida Tax Rates & Information. 5 Summary Table - New Tax Return Due Dates. 6 Summary Table - Restrictions on Transfer of Florida Homestead Property. using retroactive effective dates in agreements Tax effects flow from the date transactions occur. For example, in a recent Tax Court case, a dispute arose in regard to a change in ownership of interests in a limited liability company (LLC). Therefore, the documentation will often indicate a date the documents are signed, and a retroactive effective date for the transfer. In the case mentioned above, the taxpayers had such a retroactive effective date. However, they did not report their ownership as being changed as of the retroactive effective date in filing their tax returns. Therefore, if one is seeking a retroactive effective date for tax purposes, the first requirement is that the document be above board as to what is going on. Thus, showing the true date the agreement is signed, along with an earlier effective as of clause, is advisable. -To be effective, a retroactive effective date must be allowable under applicable state law. In the case, the Tax Court noted that this was the case in Georgia, the state involved. -The purpose of the retroactive dating cannot be to obtain an unwarranted tax benefit. The effective date of the rule will be 180 days from the date that it is published in the Federal Register, which was January 15, 2016. That makes it effective July 13, 2016.
Output:
effective date of federal tax changes