The Budget and Accounting Act of 1921 established the requirement that the President submit a budget to Congress for the upcoming fiscal year. Among other things, the proposed federal budget affords the President an...more
3/13/2023
/ C-Corporation ,
Capital Gains ,
Estate Tax ,
Federal Budget ,
Gift Tax ,
Grantor Retained Annuity Trusts (GRATs) ,
Grantor Trusts ,
IRS ,
Joe Biden ,
NIIT ,
S-Corporation ,
Tax Deferral ,
Tax Increases ,
Tax Rates
Have you ever wondered whether you were barking up the wrong tree? That the solution to a problem may be found, not in the approach to which you were already committed and invested, but in an altogether different direction?...more
3/9/2023
/ Adjusted Gross Income ,
Business Expenses ,
Closely Held Businesses ,
Foreign Corporations ,
Income Taxes ,
IRS ,
Joe Biden ,
Partnerships ,
S-Corporation ,
Self Employed ,
Tax Court ,
Tax Evasion ,
Tax Increases ,
Wealth Tax ,
Wire Transfers
State of the “Union”
Did you watch the President’s state of the union address the other night? Was it as you expected? Were you hoping for something more? Were you disappointed? Did you find it informative? Maybe...more
2/13/2023
/ Capital Assets ,
Debt ,
Dischargeable Debts ,
Fair Market Value ,
FIRPTA ,
Foreign Ownership ,
Foreign Taxpayers ,
IRS ,
Joe Biden ,
Lenders ,
Purchasers ,
Short Sales ,
State of the Union ,
Tax Liability
On October 6, 2022, the President announced three changes in the Federal government’s policy toward cannabis:
1.He pardoned all prior Federal offenses of simple possession of marijuana; 2.He urged governors to do the same...more
10/18/2022
/ California ,
Controlled Substances Act ,
Decriminalization of Marijuana ,
Department of Health and Human Services (HHS) ,
Distributors ,
Drug Possession ,
Excise Tax ,
Joe Biden ,
Marijuana ,
Marijuana Cultivation ,
Marijuana Related Businesses ,
Medical Marijuana ,
Political Campaigns ,
Popular ,
Presidential Pardons ,
Tax Credits ,
Tax Revenues
“Déjà vu All Over Again”-
The White House last week released the President’s Budget for the Fiscal Year 2023. The Budget is ambitious, but its “investments,” we are told, “are more than paid for with tax reforms focused on...more
4/8/2022
/ Capital Gains ,
Capital Gains Tax ,
Estate Tax ,
Fair Market Value ,
Family Businesses ,
Federal Budget ,
Gift Tax ,
Grantor Retained Annuity Trusts (GRATs) ,
Grantor Trusts ,
Income Taxes ,
Joe Biden ,
Rule Against Perpetuities ,
Taxable Income ,
Transfer Taxes ,
Trusts ,
Wealth Tax
Last Week-
What a week it was.
It began relatively well, with the Cowboys losing the NFC wild card game, albeit to a California team.
It ended disturbingly, with the Arizona Democratic Party censuring Senator Sinema...more
1/24/2022
/ Audits ,
Domicile ,
Holding Periods ,
Joe Biden ,
Jurisdiction ,
Lawful Permanent Residents ,
Non-Residents ,
Out-of-State Employees ,
Property Owners ,
State Taxes ,
Sustainability ,
Tax Increases ,
Taxable Income
Same old in D.C.-
On Monday, November 15, the President will sign into law the approximately $1 trillion Infrastructure Investment and Jobs Act that was finally passed by Congress when the House approved the Senate’s...more
11/15/2021
/ Beneficiaries ,
Business Assets ,
Closely Held Businesses ,
Dynasty Trust ,
Fair Market Value ,
Gift Tax ,
Infrastructure ,
IRS ,
Joe Biden ,
Limited Liability Company (LLC) ,
Net Investment Income ,
Partnerships ,
Revocable Trusts ,
Surcharges ,
Tax Advice ,
Tax Returns ,
Taxable Exchanges ,
Taxable Income ,
Transfer Taxes ,
Valuation
Tax the Rich?
A few days ago, an opinion piece that appeared in the Wall Street Journal began as follows:
“President Biden’s effort to pass the largest tax increase in U.S. history is based on the verifiably false...more
10/18/2021
/ Built-In Gains ,
C-Corporation ,
Congressional Budget Office ,
Corporate Taxes ,
Fair Market Value ,
Joe Biden ,
Limited Liability Company (LLC) ,
Liquidation ,
OECD ,
S-Corporation ,
Sale of Assets ,
Shareholders ,
Tax Increases ,
Taxable Income ,
Ways and Means Committee ,
Wealth Tax
It was quite a week, wasn’t it?-
Manchin-
Senator Manchin continued to attract a lot of attention.
To the dismay of his fellow Democrats, the West Virginian – who also chairs the Senate Energy and Natural Resources...more
10/13/2021
/ Business Ownership ,
Business Taxes ,
Capital Gains ,
Carbon Taxes ,
Clean Energy ,
Closely Held Businesses ,
Debt Ceiling ,
Estate Tax ,
Estate-Tax Exemption ,
Gift Tax ,
Gift-Tax Exemption ,
Grantor Retained Annuity Trusts (GRATs) ,
Grantor Trusts ,
Irrevocable Trusts ,
IRS ,
Joe Biden ,
OECD ,
Pandora Papers ,
Private Equity ,
SALT ,
Tax Increases ,
Tax Rates ,
Valuation ,
Ways and Means Committee
What was your month like?
If you’re a transactional professional – a class in which I include those who advise clients on the purchase and sale of businesses and investment assets, as well as those who assist clients in...more
10/5/2021
/ Budget Reconciliation ,
Business Ownership ,
Capital Gains ,
Closely Held Businesses ,
Federal Taxes ,
Joe Biden ,
Popular ,
Tax Code ,
Tax Cuts and Jobs Act ,
Tax Increases ,
Ways and Means Committee
Where Are We?
Have you seen the Triumvirate of late? No, not Julius, Pompey, and Crassus. I’m referring to more contemporary political figures, whose names and exploits are not likely to appear in volumes that will be...more
9/28/2021
/ Estate Tax ,
Fair Market Value ,
Gift Tax ,
Grantor Retained Annuity Trusts (GRATs) ,
Grantor Trusts ,
Green Book ,
Income Taxes ,
Joe Biden ,
Obama Administration ,
Tax Code ,
Tax Legislation ,
Tax Planning ,
Trust Income ,
U.S. Treasury ,
Ways and Means Committee
First Step-
Last Wednesday, the House Ways and Means Committee approved that portion of the 2022 budget legislation with which it was tasked by the Congressional Budget resolution of August 24. The text of the bill...more
9/21/2021
/ Adjusted Gross Income ,
Business Assets ,
Business Income ,
C-Corporation ,
Capital Gains ,
Corporate Taxes ,
Estate Tax ,
Gift Tax ,
Grantor Trusts ,
Investors ,
Joe Biden ,
Limited Liability Company (LLC) ,
Liquidation ,
Qualified Small Business Stock ,
S-Corporation ,
Shareholders ,
Subsidiaries ,
Surtax ,
Tax Increases ,
Taxable Income ,
Valuation ,
Wealth Tax
The Dog Days-
I’ve never much cared for the month of August. In New York, at least for me, the eighth month of the year – named by the Roman Emperor, Augustus, to honor himself – evokes memories of very warm, very humid...more
8/2/2021
/ Banks ,
Budget Reconciliation ,
Business Losses ,
Business Ownership ,
Court of Federal Claims ,
Fair Market Value ,
Infrastructure ,
Investment ,
IRS ,
Joe Biden ,
Loans ,
Partnerships ,
Tax Increases ,
Unsecured Debt
Movement Toward Tax Increases-
You may have read last week that Democrats on the Senate Budget Committee announced they had reached a deal on a budget resolution that will enable them to bypass Senate Republicans on the...more
7/19/2021
/ 1099s ,
Budget Reconciliation ,
Business Expenses ,
Corporate Officers ,
Employment Tax ,
Federal Taxes ,
FICA Taxes ,
Form 941 ,
FUTA ,
Income Taxes ,
IRS ,
Joe Biden ,
Management Fees ,
Reasonable Compensation ,
S-Corporation ,
Shareholders ,
Spouses ,
Tax Court ,
Withholding Tax
Not Good-
As Mr. Biden settled into the White House, and as the Democrats began planning how to best utilize their slim Congressional majority to enact and pay for their sweeping legislative agenda, the principal concern...more
6/29/2021
/ Budget Reconciliation ,
Capital Gains ,
Closely Held Businesses ,
Green Book ,
Joe Biden ,
Pass-Through Entities ,
Popular ,
Portfolio Companies ,
Tax Increases ,
Tax Rates ,
U.S. Treasury ,
Wealth Tax
What A Ride-
No one anticipated that the Administration’s proposed tax increases would fly through Congress easily – at least no one residing in a state in which the recreational use of marijuana has not been legalized....more
6/14/2021
/ Bipartisan Agreement ,
Budget Reconciliation ,
C-Corporation ,
Closely Held Businesses ,
Corporate Taxes ,
Decriminalization of Marijuana ,
Department of Labor (DOL) ,
Employment Tax ,
FICA Taxes ,
Financial Adviser ,
Infrastructure ,
IRS ,
Joe Biden ,
Limited Liability Company (LLC) ,
Marijuana ,
Medicare ,
Net Investment Income ,
Partnerships ,
Pass-Through Entities ,
Popular ,
Reasonable Compensation ,
S-Corporation ,
Shareholders ,
Social Security Taxes ,
Wealth Tax
Recap-
Last week, we considered several of the revenue proposals included in the Biden Administration’s 2022 Budget that are probably of interest – or should we say, “of concern”? – to the owners of closely held...more
6/7/2021
/ C-Corporation ,
Capital Contributions ,
Capital Gains Tax ,
Closely Held Businesses ,
Compensation ,
Fair Market Value ,
Federal Budget ,
Gift Tax ,
Green Book ,
Hedge Funds ,
Income Taxes ,
Investment Partnerships ,
IRS ,
Joe Biden ,
Limited Liability Company (LLC) ,
Long-Term Investment Funds ,
Partnerships ,
Profits Interests ,
S-Corporation ,
Tax Equity ,
Tax Equity Partnership ,
Transfer Taxes ,
Valuation ,
Vested Benefits
Ask the owner of a closely held business to describe their most recently recurring nightmare and you are likely to get an earful regarding the prospect of an increased federal income tax on their profits, an increased federal...more
5/17/2021
/ Biden Administration ,
Bona Fide Purchaser ,
Capital Gains ,
Cash Transactions ,
CCA ,
Closely Held Businesses ,
Estate Tax ,
Fair Market Value ,
Federal Taxes ,
Income Taxes ,
Investigations ,
IRS ,
Joe Biden ,
OCC ,
Promissory Notes ,
Tax Advice ,
Tax Deferral ,
Tax Increases ,
Tax Liability ,
Unsecured Debt
Go After Real Estate?
During the 2020 presidential campaign, there was one segment of the “rich” for which then-candidate Biden seemed to have reserved some of his harshest criticism – wealthy real estate investors....more
5/11/2021
/ Capital Gains ,
Estate Tax ,
Income Taxes ,
Installment Agreements ,
Internal Revenue Code (IRC) ,
Investment Property ,
Joe Biden ,
Like Kind Exchanges ,
Political Campaigns ,
Real Estate Investments ,
S-Corporation ,
Step-Up Basis ,
Tax Increases ,
Tax Planning
A Night to Remember?
Did you listen to the President’s speech last Wednesday? He addressed a joint session of Congress to pitch the Administration’s $1.8 trillion American Families Plan. Due to COVID-related...more
5/3/2021
/ Capital Assets ,
Capital Gains ,
Closely Held Businesses ,
Corporate Taxes ,
Estate Tax ,
Fair Market Value ,
Gift Tax ,
IRS ,
Joe Biden ,
Liquidity ,
Qualified Small Business Stock ,
Tax Cuts and Jobs Act ,
Tax Fraud ,
Tax Liability ,
Taxable Income ,
Wealth Tax
In advance of the President’s address to Congress this evening, the White House this morning released a summary of Mr. Biden’s proposed changes to the Internal Revenue Code. These changes, together with his previously...more
“Yeah, I’m the Tax Man”
Last week, several media outlets reported that Mr. Biden will soon propose that Congress increase the federal income tax rate applicable to long-term capital gains recognized by individual...more
4/26/2021
/ American Taxpayer Relief Act of 2012 (ATRA) ,
Baby Boomers ,
Budget Reconciliation ,
Business Assets ,
Business Ownership ,
Business Taxes ,
Capital Gains ,
Census ,
Closely Held Businesses ,
Deferred Compensation ,
Depreciation ,
Economic Downturn ,
Income Taxes ,
IRS ,
Joe Biden ,
Loans ,
Pass-Through Entities ,
Personal Property ,
Popular ,
Retirement Funds ,
Tangible Property ,
Tax Deductions ,
Tax Increases ,
Tax Reform ,
Tax Relief Act of 2010 ,
Tax-Free Transfers ,
Taxable Income
According to Justice Learned Hand, “Any one may so arrange his affairs that his taxes shall be as low as possible; he is not bound to choose that pattern which will best pay the Treasury; there is not even a patriotic duty to...more
4/5/2021
/ Business Expenses ,
Business Taxes ,
Capital Gains ,
Enforcement ,
Estate Tax ,
False Claims Act (FCA) ,
Infrastructure ,
IRS ,
Joe Biden ,
New York ,
Qui Tam ,
Shell Corporations ,
State Attorneys General ,
State Taxes ,
Tax Audits ,
Tax Avoidance ,
Tax Increases ,
Tax Liability ,
Tax Planning ,
Wealth Tax ,
Whistleblowers ,
Withholding Tax
Are the rich making enough of a contribution to society? Are they bearing their fair share of taxes? Many New York legislators don’t think so.
Following the elections of November 2020, the State’s Democratic party secured...more
3/30/2021
/ Alternative Minimum Tax ,
American Rescue Plan Act of 2021 ,
C-Corporation ,
Capital Gains Tax ,
Coronavirus/COVID-19 ,
Corporate Taxes ,
Estate Tax ,
Fiscal Year ,
Governor Cuomo ,
Impeachment ,
Income Taxes ,
Investment ,
Joe Biden ,
New York ,
Nursing Homes ,
SALT ,
Sexual Harassment ,
State Attorneys General ,
State Budgets ,
State Taxes ,
Surcharges ,
Tax Increases ,
Tax Rates ,
Taxable Income ,
Wealth Tax