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Form 1099-K Implementation for E-Commerce Platforms Delayed for 2023

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

“Accidental Americans” Must Pay US Tax On Worldwide Income And Provide Detailed US Tax Reporting

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

Starting An Active Business In An Opportunity Zone

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

Business Succession Planning – Should I Own My Business In A Trust?

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

Nelson: IRS Prevails In Defined Value Provision Case

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

Treasury Extends BOTH Deadline To Pay Income Taxes And Deadline To File Income Taxes By 90 Days

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

Treasury Extends Deadline To Pay Income Taxes By 90 Days

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

Supreme Court Unanimously Rules That States Cannot Tax Trusts Based Solely On Location Of Beneficiaries

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

Code §962 Election Is An Option For GILTI Planning

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

Should I Be A C Corp? Choice Of Entity After Tax Reform

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

Tax Court Holds That Foreign Corporation’s Sale Of A Partnership Interest Not Taxable In US

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

The Repeal of the New Jersey Estate Tax: Is it Now Safe to Move Back to New Jersey?

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

Estate Planning and Administration – Be Prepared for the Year That Follows the Death of a Loved One

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

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