There is no denying that many parts of the Code are complex and, in some cases, too obscure for many “laypersons” to comprehend. Over time, this reality spawned the need for advisers who are both knowledgeable and experienced...more
8/12/2024
/ Business Expenses ,
Capital Gains ,
Fair Market Value ,
Foreign Persons ,
Internal Revenue Code (IRC) ,
IRS ,
Limited Liability Company (LLC) ,
Non-Resident Aliens ,
Partnership Interests ,
Tax Cuts and Jobs Act ,
Tax Deductions ,
Taxable Income
In less than four months, the citizens of the United States will be electing their next President to a four-year term. They will also be deciding which of the two major political parties will “control” the Senate, the House,...more
7/11/2024
/ Apportionment ,
C-Corporation ,
Conservatives ,
Controlled Foreign Corporations ,
Foreign Corporations ,
IRS ,
Moore v US ,
Partnerships ,
Pass-Through Entities ,
Presidential Elections ,
Repatriation ,
S-Corporation ,
SCOTUS ,
Shareholders ,
Sixteenth Amendment ,
Tax Cuts and Jobs Act ,
Tax Deferral ,
Tax Liability ,
Term Limits
The Long-Term View-
Among its core functions, federal tax policy seeks to encourage those behaviors among businesses that, in the long run, will have a lasting positive effect upon the nation’s economy as a whole. ...more
1/26/2024
/ Federal Taxes ,
Gift Tax ,
Income Taxes ,
Internal Revenue Code (IRC) ,
IRS ,
Itemized Deductions ,
MACRS ,
Modification ,
Sunset Provisions ,
Tax Cuts and Jobs Act ,
Tax Deductions ,
Tax Exemptions ,
Tax Legislation ,
Tax Rates
This is The End-
I have dreaded the year end for as long as I can remember. As a teenager and then as a young adult I associated the final quarter of the year, and especially the period beginning on Thanksgiving and...more
12/20/2023
/ Business Ownership ,
Capital Gains ,
Carried Interest ,
Closely Held Businesses ,
Estate Tax ,
Federal Taxes ,
Gift Tax ,
Grantor Retained Annuity Trusts (GRATs) ,
Income Taxes ,
Investors ,
IRS ,
Tax Cuts and Jobs Act ,
Tax Planning ,
Transfer Taxes ,
Trusts ,
U.S. House
Many of you, perhaps most, may have read about a case that will be heard by the U.S. Supreme Court during its current term. The case, Moore v. United States, comes out of the Ninth Circuit Court of Appeals. The Supreme Court...more
10/13/2023
/ Amicus Briefs ,
Apportionment ,
Certiorari ,
Controlled Foreign Corporations ,
Duties ,
Equitable Distribution ,
Foreign Corporations ,
Foreign Investment ,
Foreign Partner ,
Income Taxes ,
Internal Revenue Code (IRC) ,
Net Investment Income ,
Pass-Through Entities ,
Reinvestment Funds ,
SCOTUS ,
Shareholders ,
Sixteenth Amendment ,
Subpart F ,
Tax Cuts and Jobs Act ,
Taxation ,
Ways and Means Committee
Losses Weren’t Always Bad-
Most tax advisers are aware that, prior to the Tax Reform Act of 1986 (the “TRA”),[i] the Code placed few limitations on the ability of an individual taxpayer to use deductions from a particular...more
7/27/2023
/ Business Losses ,
Capital Contributions ,
Deficit Reduction ,
IRS ,
Limited Liability Company (LLC) ,
Membership Interest ,
Net Operating Losses ,
Non-Recourse Loans ,
Partnership Interests ,
Partnerships ,
Passive Losses ,
Promissory Notes ,
Tax Court ,
Tax Cuts and Jobs Act ,
Tax Deductions ,
Tax Losses ,
Tax Planning ,
Tax Reform
It’s Complicated-
The Code includes a number of complex rules that are aimed at those overseas business and investment activities of U.S. taxpayers that Congress has determined may result in the improper deferral or...more
7/11/2023
/ CARES Act ,
Controlled Foreign Corporations ,
Foreign Corporations ,
Foreign Earned Income ,
Foreign Investment ,
Foreign Ownership ,
Foreign Tax ,
Income Taxes ,
Internal Revenue Code (IRC) ,
IRS ,
Parent Corporation ,
Senate Finance Committee ,
Stock Ownership ,
Subpart F ,
Tax Cuts and Jobs Act ,
Tax Deferral
Summer Break?
After the last couple of weeks, I’m looking forward to Congress’s summer vacation. I’m pretty sure our elected representatives feel the same way, though it is unclear at this point when they will be heading...more
8/1/2022
/ Acts of Congress ,
Capital Gains ,
Carried Interest ,
Federal Reserve ,
Holding Periods ,
Interest Rates ,
Partnership Interests ,
Partnerships ,
Price Inflation ,
Profits ,
Publicly-Traded Companies ,
Tax Cuts and Jobs Act ,
Tax Increases ,
Tax Loopholes ,
U.S. Commerce Department
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
Extra, Extra!-
Last Friday afternoon, as millions of unsuspecting Americans prepared for the long Memorial Day weekend – for many, perhaps, their first mask-less holiday celebration in almost 15 months – the Biden...more
6/2/2021
/ Adjusted Gross Income ,
Biden Administration ,
C-Corporation ,
Capital Gains ,
Closely Held Businesses ,
Corporate Taxes ,
Dynasty Trust ,
Fair Market Value ,
Family Businesses ,
Federal Budget ,
Fiscal Year ,
Gift Tax ,
Green Book ,
Interest Rates ,
Irrevocable Trusts ,
IRS ,
Like Kind Exchanges ,
Loans ,
Long-Term Investment Funds ,
Popular ,
Public Charities ,
Revocable Trusts ,
Spouses ,
Tax Cuts and Jobs Act ,
Tax Increases ,
Taxable Income ,
Transfer Taxes ,
Trust Assets ,
Trusts ,
U.S. Treasury
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
New York’s Governor Cuomo is having a bad 2021. Some may attribute this to his hubris or to karma; others may point to an emboldened, and now veto-proof, progressive State Legislature; many will claim that Mr. Cuomo is paying...more
4/12/2021
/ Adjusted Gross Income ,
Corporate Taxes ,
Estate Tax ,
Governor Cuomo ,
Income Taxes ,
Low-Income Issues ,
New York ,
Pass-Through Entities ,
Popular ,
Qualified Opportunity Funds ,
Real Estate Transfers ,
State Budgets ,
State Taxes ,
Tax Code ,
Tax Cuts and Jobs Act ,
Tax Incentives ,
Tax Increases ,
Taxable Income ,
Wealth Tax
The New York state budget deal announced yesterday includes a workaround of the temporary federal limit on state and local tax deductions (the SALT cap). The provision was part of Gov. Cuomo’s initial budget proposal in...more
4/7/2021
/ Business Income ,
Governor Cuomo ,
Income Taxes ,
IRS ,
Itemized Deductions ,
New York ,
Pass-Through Entities ,
S-Corporation ,
SALT ,
Shareholders ,
State and Local Government ,
State Budgets ,
State Taxes ,
Tax Cuts and Jobs Act ,
Tax Deductions ,
Taxable Income