Once Removed Episode 12: SLATs and the Case of McKim vs. McKim
Adult-Use Marijuana Legalization in NYS – What You Need to Know
HIPPER THAN HIP
WHERE EAGLES DARE-INTRODUCING MALTA SPLIT DOLLAR
SO VERY HARD TO GO (NOT)! In Pursuit of Puerto Rican Tax Incentives
IT NEVER RAINS IN SOUTHERN CALIFORNIA - INTRODUCING THE MALTA FREEZE
THE ACCIDENTAL ENTREPRENEUR PART V video
THE ACCIDENTAL ENTREPRENEUR PART V Podcast
Qualified Opportunity Zone Fund Investments
Impact of Tax Reform on Charitable Giving
Podcast - Chamber of Commerce v. Internal Revenue Service
The IRS has issued new guidance to prevent related parties from using partnerships to achieve tax benefits through basis-shifting among assets. The IRS recently released a guidance package aimed at preventing...more
On June 17, 2024, the IRS announced the formation of a dedicated group in the Office of Chief Counsel specifically focused on developing guidance on partnerships, which is expected to work with a new “passthrough working...more
The Internal Revenue Service (IRS) is increasing audits on corporate aircraft use for high-net-worth individuals, large corporations and complex partnerships as part of its new initiative using Inflation Reduction Act funding...more
Limited liability companies (LLCs) offer significant tax flexibility – for one thing they can elect to be treated as disregarded entities, partnerships, C corporations, or S corporations, and can even shift between those tax...more
It appears that many of the country’s colleges and universities believe they have not already contributed enough to the decline of American education and to the erosion of our society, generally. These institutions of...more
Recent Government actions suggest that third-party promoters and potentially hundreds of taxpayers may be entering into abusive trust arrangements aimed at unlawfully eliminating or deferring federal income taxes....more
For some time, promoters have shopped around an arrangement known as a “section 643(b) trust,” known alternatively as a “non-grantor, irrevocable, complex, discretionary, spendthrift trust.” On August 9, 2023, IRS Chief...more
We have heard from several clients asking about ways to help their employees that suffered tremendously from the wrath of Hurricane Ian. While there are a variety of Federal, State and private relief efforts underway,...more
On August 5, 2022, the US Court of Appeals for the District of Columbia Circuit upheld the US Tax Court’s bench opinion in favor of partners and investors in a refined coal business. The Internal Revenue Service (IRS) has...more
Since coming into effect in January 2018, Subchapter Z of the US Tax Code—also known as the opportunity zone provisions—has enabled investors to pour billions of dollars into a broad array of businesses, from real estate...more
In a previous post, we discussed the tax implications for U.S. beneficiaries who receive a distribution from a foreign trust. That discussion assumed that the trust in question was, in fact, a foreign trust for U.S. federal...more
On April 17, 2019, Treasury issued its second installment of proposed regulations relating to Qualified Opportunity Zones (“QOZs”). The regulations are 169 pages in length, and (as suspected) are fairly complex. Nevertheless,...more
On March 27, 2019, the Senate Finance Committee launched an investigation into the abuse of syndicated conservation easement transactions. The transactions being investigated involve promoters selling interests in tracts of...more
There has been a lot of “buzz” in the media about Qualified Opportunity Zones (“QOZs”). Some of the media accounts have been accurate and helpful to taxpayers. Other accounts, however, have been less than fully accurate, and...more
• With Democrats taking control of the U.S. House of Representatives, tax provisions affecting tribal governments and their members are once again on the table for discussion. • This notice provides an overview of seven...more
• Proposed regulations issued on October 19 provide welcome guidance to asset managers regarding the formation of qualified opportunity funds (QOFs) that may provide investors with the following three tax benefits: (1)...more
On October 19, 2018, the U.S. Treasury Department and Internal Revenue Service (“IRS”) issued long-awaited and much anticipated proposed regulations (the “Proposed Regulations”) relating to the Opportunity Zone Fund (“OZ...more
• Even though practitioners are awaiting proposed regulations on the new opportunity zone provision, interested parties are already starting to set up qualified opportunity funds to pool investor capital. • States, cities,...more
Charitable organizations work hard to maintain exempt status. These organizations operate in a highly regulated landscape: In exchange for enjoying freedom from income taxes, they must comply with strict organizational and...more
BACKGROUND - The Tax Cuts and Jobs Act (“TCJA”) creates, modifies or eliminates a number of employment and employee fringe benefit related provisions of the Code. Both employers and employees need to be aware of these...more
Good news for taxpayers who have, or who are considering, abandoning an interest in an underperforming partnership. Earlier this week the Fifth Circuit overturned the Tax Court’s 2013 decision in Pilgrim’s Pride, clearing...more
On January 9, 2014, the Internal Revenue Service (“IRS”) issued a revised version of previously released Rev. Proc. 2014-12, providing a safe harbor for the allocation of IRC Sec. 47 rehabilitation tax credits in tax credit...more
A few weeks after the Internal Revenue Service (IRS) stated that it will apply a “place of celebration” rule in recognizing same-sex spouses for purposes of the Internal Revenue Code (including with respect to employee...more