Earlier this year, the OECD observed there has been a significant increase in global wealth inequality over the last two decades. It also acknowledged that “taxation is a key instrument . . . that governments have at their...more
5/16/2024
/ Audits ,
Capital Gains ,
Federal Budget ,
Foreign Governments ,
Inflation Reduction Act (IRA) ,
IRS ,
Net Investment Income ,
OECD ,
Presidential Elections ,
Surtax ,
Tax Authority ,
Tax Avoidance ,
Tax Increases ,
Tax Liability ,
United Nations ,
Wealth Tax ,
Whistleblowers
Last week, Sen. Warren reintroduced her “Ultra-Millionaires” wealth tax proposal to the Senate. Query her timing. The measure has the proverbial snowball’s chance in Hell of being enacted by this Congress.Perhaps the Senator...more
3/26/2024
/ Biden Administration ,
Business Entities ,
Business Income ,
Business Losses ,
Capital Gains ,
Closely Held Businesses ,
Corporate Taxes ,
Federal Budget ,
Federal Taxes ,
Income Taxes ,
Investment ,
Limited Liability Company (LLC) ,
Medicare Taxes ,
NIIT ,
Partnerships ,
S-Corporation ,
Self-Employment Tax ,
Shareholders ,
Tax Deductions ,
Tax Rates ,
Taxable Income ,
U.S. Treasury ,
Wealth Tax
Last week, the IRS announced “the start of a sweeping, historic effort to restore fairness in tax compliance by shifting more attention onto high-income earners, partnerships, large corporations and promoters abusing the...more
9/14/2023
/ Artificial Intelligence ,
Balance Sheets ,
Compliance ,
Highly Compensated Employees ,
Inflation Reduction Act (IRA) ,
IRS ,
Limited Partnerships ,
S-Corporation ,
Self Employed ,
Self-Employment Tax ,
Tax Court ,
Tax Debt ,
Tax Evasion ,
Tax Liability ,
Taxable Income ,
Wealth Tax
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
According to a report issued by the National Association of Realtors a couple of days ago, last year saw a large outmigration of people from California and New York, while Florida and Texas experienced a comparably large...more
2/3/2023
/ Beneficiaries ,
Closely Held Businesses ,
Domicile ,
Estate Planning ,
Exemptions ,
Gifts ,
Grantor Trusts ,
Income Taxes ,
New York ,
Non-Residents ,
Settlors ,
State and Local Government ,
Tax Liability ,
Trusts ,
Value Appreciation ,
Wealth Tax
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
1/26/2023
/ Capital Gains ,
Estate Tax ,
High Net-Worth ,
Income Taxes ,
Net Investment Income ,
New York ,
Selling a Business ,
State Taxes ,
Tax Increases ,
Tax Rates ,
Taxable Income ,
Trusts ,
Wealth Tax
Taxing the Rich-
During the last couple of months, as we headed into what most folks – excluding transactional attorneys – call the “Holiday Season,”[i] tax authorities from around the globe have been calling for increased...more
At different times over the course of the last thirty days or so, I have seen reports describing various plans to increase income taxes and/or wealth taxes on the “rich” that have either been endorsed or proposed by the likes...more
10/26/2022
/ Board of Directors ,
China ,
General-Business ,
Governor Newsom ,
Income Taxes ,
IRS ,
Limited Liability Company (LLC) ,
S-Corporation ,
Shareholder Distributions ,
Shareholders ,
Wealth Tax
Tax Alchemy?
How many of you remember Section 138509 of the Ways and Means Committee’s markup last September of what would have been the Build Back Better Act? (A moment of silence, please.) Allow me to jog your memory....more
7/26/2022
/ Capital Gains ,
Domestic Partnership ,
Fair Market Value ,
IRS ,
Like Kind Exchanges ,
Partnerships ,
Pass-Through Entities ,
Property Owners ,
S-Corporation ,
Shareholder Distributions ,
Shareholders ,
Stocks ,
Tax Deferral ,
Taxable Exchanges ,
Ways and Means Committee ,
Wealth Tax
“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
Counting the Days?-
We are 302 days away from the national mid-term elections, to be held November 8, 2022, yet the first full week of the new year has already highlighted some of the economic issues with which the...more
1/12/2022
/ Appraisal ,
Business Ownership ,
Business Valuations ,
Closely Held Businesses ,
Estate Planning ,
Estate Tax ,
Fair Market Value ,
Federal Budget ,
Gift Tax ,
Grantor Retained Annuity Trusts (GRATs) ,
Grantor Trusts ,
Investment Banks ,
IRS ,
Letters of Intent ,
Mark-To-Market ,
Medicare ,
Net Investment Income ,
Qualified Small Business Stock ,
Stocks ,
Surtax ,
Target Company ,
Tax Increases ,
Wealth Tax
Tax the Rich?
The President’s plan for a tax regime that would ensure the rich pay their “fair share” of the cost of implementing his programs has come one step closer to being realized . . . maybe . . . well, sort of ....more
11/23/2021
/ Adjusted Gross Income ,
C-Corporation ,
Capital Gains ,
Capital Gains Tax ,
Corporate Taxes ,
Estate Tax ,
Gift Tax ,
Grantor Retained Annuity Trusts (GRATs) ,
Income Taxes ,
Infrastructure ,
Inter Vivos Gifts ,
IRS ,
Mark-To-Market ,
Net Investment Income ,
Social Security Taxes ,
Tax Code ,
Tax Court ,
Tax Liability ,
Tax Returns ,
Transfer Taxes ,
Valuation ,
Wealth Tax
It Seemed Like a Good Idea-
In July of this year, one of my partners, who chairs the board of a local grantmaking public charity, asked if I would present at a CLE program to be sponsored by the charity on October 28 (last...more
11/1/2021
/ Budget Reconciliation ,
Capital Gains ,
Corporate Taxes ,
Federal Budget ,
Grantor Trusts ,
Green Book ,
Income Taxes ,
IRS ,
Like Kind Exchanges ,
Popular ,
SALT ,
Tax Increases ,
Ways and Means Committee ,
Wealth Tax
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
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
Living the Dream-
“How was your weekend?” Thank you for asking. Awful.
“Why?” you ask. (Humor me. Pretend you’re interested.) I’ll tell you. One word, with 535 syllables: Congress.
When the reconciliation budget...more
9/13/2021
/ Biden Administration ,
Business Ownership ,
Business Taxes ,
Capital Gains ,
Corporate Taxes ,
Green Book ,
Income Taxes ,
Partnerships ,
Popular ,
Reconciliation ,
Tax Increases ,
Tax Revenues ,
Wealth 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
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
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
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