Under a new federal law enacted in 2021 (the “American Rescue Plan” or the “New Law”), Venmo, Pay Pal, Cash App, Etsy, eBay and other e-commerce platforms are now required to send individual users income tax Form 1099-K for...more
We have had several matters recently with “Accidental Americans” – that is, non-US persons who became US tax residents by staying in the US for a sufficient number of days.
This frequently happens in an understandable...more
This short article outlines the requirements for starting an active business in a qualified opportunity zone (“QOZ”).
The US tax legislation that created QOZs was enacted in early 2018, and is intended to encourage...more
Closely-held businesses come in all shapes and sizes. Some owners own 100% of their businesses. Some have partners. Some have children in the business. Some do not. A common question that a client asks the business and...more
3/3/2021
/ Asset Protection ,
Business Succession ,
Closely Held Businesses ,
Estate Planning ,
Estate Tax ,
Family Businesses ,
Gift Tax ,
Income Taxes ,
Partnerships ,
Succession Planning ,
Surviving Spouse ,
Trusts
On June 10, 2020, in Nelson v. Commissioner, T.C. Memo 2020-81, the Tax Court ruled in favor of the IRS and against a taxpayer who attempted to use a defined value provision to value a transfer of assets.
The taxpayer’s...more
Today, the Treasury announced that it will also be pushing back the April 15th deadline to file 2019 income tax returns. As a result, taxpayers will not need to pay income taxes owed for 2019 and will not need to file 2019...more
Due to the Coronavirus Pandemic, the Treasury announced Tuesday that it will be pushing back the April 15th deadline to pay income taxes owed for 2019 by 90 days. In other words, until July 15, 2020, no taxpayer will be...more
In a closely-watched decision, the U.S. Supreme Court unanimously ruled that a beneficiary’s residence within a state alone does not subject a trust to such state’s income tax. In North Carolina Dept. of Revenue v. Kimberley...more
6/26/2019
/ Beneficiaries ,
Due Process ,
Estate Tax ,
Exclusive Control ,
Forum State ,
In-State Beneficiaries ,
Income Taxes ,
Minimum Contacts ,
North Carolina Department of Revenue v The Kimberley Rice Kaestner 1992 Family Trust ,
SCOTUS ,
State Taxes ,
Trust Distributions ,
Trustees ,
Trusts
The 2017 Tax Act added a new tax on US shareholders of controlled foreign corporations (“CFCs”), the tax on Global Intangible Low-Taxed Income (“GILTI”). GILTI often includes active business income and thus has a widespread...more
The recently enacted 2017 Tax Act (originally called the Tax Cuts and Jobs Act – “Tax Reform”) made major changes to the US tax system. Because C corporations (“C corps”) are now taxed at a flat 21% federal income tax rate,...more
The US Tax Court recently held that a foreign corporation is not subject to US income tax on the sale of a partnership interest where the partnership conducts a US business. In so holding, the Tax Court rejected a 26 year...more
On October 14, 2016, Governor Christie signed into law a transportation funding bill that also included the repeal of the New Jersey Estate Tax. Here is what you need to know: -
The New Jersey Estate Tax repeal will be...more
The loss of a loved one is a traumatic event and it can be among the most challenging of times to make important financial decisions. Proactive planning with an attorney and financial planner can significantly lessen the...more