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As the ball drops in Times Square on December 31, 2024, many of the tax breaks established by the Tax Cuts and Jobs Act (TCJA) of 2017 will disappear. While the TCJA made some permanent tax cuts, a number of tax cuts and...more
Last Thursday, New York State Senator Gustavo Rivera, who represents the 33rd District (basically, the northwestern quadrant of The Bronx), proposed legislation that seeks to collect more taxes from the State’s high-income...more
Our annual estate and tax planning newsletter discusses certain concepts and techniques that should be considered in 2022 by our clients and friends in California. Perhaps the most important recent development was the failure...more
On June 21, 2019, the U.S. Supreme Court issued its opinion in North Carolina Department of Revenue v. Kimberly Rice Kaestner 1992 Family Trust. This unanimous decision stated that the State of North Carolina may not tax...more
On June 21, 2019, the U.S. Supreme Court issued an opinion limiting the ability of a state to impose income taxes on a trust when the trust’s connection with the taxing state is minimal. The case is styled North Carolina...more
In North Carolina Department of Revenue v. Kimberley Rice Kaestner 1992 Family Trust, Case No. 18-457, 588 U.S. __ (2019), the Supreme Court revived the two-prong test from Quill v. North Dakota, 504 U.S. 298 (1992) and held...more
On July 2, 2019, the North Carolina Department of Revenue issued a notice setting December 21, 2019, as the deadline for certain taxpayers to file amended returns or tax refund claims based on the U.S. Supreme Court decision...more
Kaestner ruled that a state's taxation of a trust's income, where the only connection to the state was an in-state beneficiary, violates the Due Process Clause. On June 21, 2019, the United States Supreme Court unanimously...more
Supreme Court Ruling in North Carolina Department of Revenue v. Kimberley Rice Kaestner 1992 Family Trust, 588 U.S. [TBD] and its Relevance to Income Taxation of Accumulated Income in California Trusts - The Supreme Court...more
On June 21, 2019, the United States Supreme Court decided North Carolina Dept. of Revenue v. Kimberly Rice Kaestner 1992 Family Trust (hereinafter, “Kaestner”). In a unanimous opinion delivered by Justice Sotomayor, the Court...more
Oftentimes, a family business will be owned in part or entirely by one or more irrevocable trusts. Whether those trusts are subject to state income tax depends on the location of any one or more of: (1) the...more
Last week, the US Supreme Court ruled that North Carolina may not tax a trust’s income when the trust’s only contact with the state is the in-state residence of discretionary beneficiaries. The Due Process Clause requires a...more
There’s big news in the tax and trusts and estates world. The U.S. Supreme Court released its opinion in the North Carolina Dept. of Revenue v. Kimberley Rice Kaestner 1992 Family Trust case...more
On June 21, the U.S. Supreme Court issued a unanimous decision in North Carolina Department of Revenue v. Kimberley Rice Kaestner 1992 Family Trust (Kaestner), holding that a trust is not subject to fiduciary income tax in a...more
On June 21, 2019, the United States Supreme Court unanimously held, in North Carolina Department of Revenue v. Kimberley Rice Kaestner 1992 Family Trust, that the North Carolina Department of Revenue could not...more
The U.S. Supreme Court recently issued its decision in North Carolina Department of Revenue v. Kimberley Rice Kaestner 1992 Trust. The Court unanimously determined that the residency of in-state beneficiaries alone is an...more
On June 21, 2019 the United States Supreme Court issued its opinion for North Carolina Department of Revenue v. Kimberly Rice Kaestner 1992 Family Trust. Not surprisingly, based on how oral argument went, the Court ruled that...more
On Friday, June 21, 2019, the Supreme Court of the United States ruled in North Carolina Department of Revenue v. Kimberley Rice Kaestner 1992 Family Trust that a state cannot tax a trust based only on a trust beneficiary’s...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
On June 21, 2019, the U.S. Supreme Court issued a unanimous opinion, delivered by Justice Sotomayor, in North Carolina Department of Revenue v. Kimberley Rice Kaestner 1992 Family Trust, holding that the North Carolina...more
One year after dropping the landmark Wayfair decision, the Supreme Court returned to the world of state taxes in North Carolina Department of Revenue v. Kimberley Rice Kaestner 1992 Family Trust. Our State & Local Tax Group...more
On June 21, 2019, the U.S. Supreme Court decided North Carolina Department of Revenue v. Kimberley Rice Kaestner 1992 Family Trust, holding that The Due Process Clause does not allow a state to tax a trust’s income where the...more
On April 16, 2019, the U.S. Supreme Court heard arguments in Kaestner v. North Carolina Department of Revenue. The case will address the extent of the state’s authority to tax the income of certain trusts. The trustees of the...more
The U.S. Supreme Court will have the final word in the ongoing challenge to North Carolina’s statute taxing trust income, as it agreed on January 11 to hear arguments in North Carolina Dept. of Revenue v. Kaestner Family...more
The newly enacted U.S. tax law makes significant changes to provisions of the Internal Revenue Code affecting high net worth individuals, their investment entities and family offices. These changes are likely to spur gift...more