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Craig Smalley

Craig W. Smalley, MST, EA, is the Founder and CEO of CWSEAPA, PLLC. He has been admitted to practice before the Internal Revenue Service as an Enrolled Agent and has a Master’s Certificate in Taxation from UCLA. In practice since 1994, Craig is well-versed in U.S Tax Law and U.S. Tax Court cases, and specializes in individual, partnership, and corporate taxation for high-net-worth clients; entity structuring and restructuring; and representation before the IRS regarding negotiations, audits and appeals. Craig is currently a columnist for CPA Practice Advisor and AccountingWEB and has had 12 books published. His articles have been featured in publications including the Wall Street Journal, The New York Times, and Christian Science Monitor, and he has been interviewed and appeared as a featured guest on numerous radio shows and podcasts. Craig can be reached at craig@craigwsmalleyea.com.

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Digital Currency

Taxation and Initial Coin Offerings

Time and time again, I talk to companies that are in the middle of an ICO, and the way they set up their companies, are crazy. I have an appointment next week with an ICO company, that has set up a company in the Cayman Islands, which has no tax.

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Is IRC §280E a Tax or a Penalty?

There was an interesting appeals case, that turned into a Writ of Certirori[1]. Green Solutions Retail, Inc. v. United States, started in US Tax Court. Green Solutions is a Colorado cannabis dispensary, that had its 2013, and 2014 tax returns audited ...

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Small Business

Captive Insurance

A captive insurer is generally defined as an insurance company that is wholly owned and controlled by its insureds; its primary purpose is to insure the risks of its owners, and its insureds benefit from the captive insurer’s underwriting profits.

What California Cannabis Businesses Need to Know About Taxes

In January, California went recreational, and they did it right. They offer several licenses. They offer grow licenses, dispensary (club as it is called there) licenses, delivery licenses, and micro-business licenses. The grow, club, and delivery ...

Technology

Will Congress Just Fund the IRS Already?

And here we are. Again the IRS, is getting the shaft. The president wants to cut the IRS’s, already thin budget, by $234 million. You would think that a tax accountant would be happy about this. However, I have been here since 1994, I have seen the ...

IRC Sec 751 in a Nutshell

With a Section 751 Transfer, we are usually talking about a commercial building or an appreciable asset. For this article, we are going to stick with a commercial building, because it is easier to explain. Let’s say you have a partner that has a ...

Digital Currency

The Important Change to IRC §1031 Exchanges With the New Tax Law

A Section 1031 Exchange is a like-kind exchange. Before the new tax law, if you had anything classified as property, you could exchange that property for property that was like-kind, and avoid the capital gains tax on the transactions.

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Estate Planning and the 2018 Tax Reform Law

For most practitioners the estate tax hasn’t come into play for many years. Instead of eliminating the estate tax, the estate tax exemption has been raised to $11 million for an individual, and $22 million for a married couple that elects portability.

Friends & Family: How Many Free Tax Returns Do You Prepare?

I don’t want to sound crass, but how I got to this point was there was a mom of my wife’s best friend. She got in trouble with back taxes, and I did an Offer in Compromise pro bono for her. Part of the offer, is that she had to file her return on time,...

No More Free Tax Consultations

My client acquisition cost is through the roof. It’s not actual money that I am spending, it is my time. When I meet with a new client, I ask for the last three years tax returns, both business and personal, before we meet, so that I can review them.

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Small Business

What are B-Corporations and L3C’s?

A B-Corporation, is short for a Benefit Corporation. These B Corps, are for-profit companies that have been certified by the non-profit B Lab. Some big companies like Ben & Jerry’s, Patagonia, Etsy, and others, have taken the plunge and become B-Corps.

Digital Currency

December 2017 Tax Channel

In the case of cryptocurrency, we have a dichotomy where the IRS is treating the currency as property for income taxes, and then asking that the property be reported as a foreign bank account.