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Form 1099-K Implementation for E-Commerce Platforms Delayed for 2023

Under a new federal law enacted in 2021 (the “American Rescue Plan” or the “New Law”), Venmo, Pay Pal, Cash App, Etsy, eBay and other e-commerce platforms are now required to send individual users income tax Form 1099-K for...more

IRS Issues Revenue Ruling Holding that Assets Held in an Irrevocable Grantor Do Not Receive a Step-Up in Basin at Death

In a recently-issued Revenue Ruling (Rev Rul 2023-02), the IRS has held that the basis of the assets in an irrevocable grantor trust, where the assets are not included in the grantor’s gross estate for federal estate tax...more

The Insurance-Only LLC – A Consideration for Buy-Sell Agreements

When business owners have partners and consider their succession planning, the topic of a buy-sell agreement comes up. This post discusses the possible use of an “insurance-only LLC” as part of a buy-sell....more

Nelson: IRS Prevails In Defined Value Provision Case

On June 10, 2020, in Nelson v. Commissioner, T.C. Memo 2020-81, the Tax Court ruled in favor of the IRS and against a taxpayer who attempted to use a defined value provision to value a transfer of assets. The taxpayer’s...more

Tax Planning In Light Of Business Hardship: Tax Relief Issues In The CARES Act

Businesses dealing with the present economic downturn may find relief from taxation and potential tax refund options under existing tax law as recently amended by the CARES Act....more

Tax Planning In Light Of Business Hardship: Cancellation Of Debt Income

In light of the coronavirus pandemic and significant economic downturn, this blog post briefly discusses questions that are commonly being asked right now regarding the income tax treatment of cancellation of indebtedness...more

Treasury Extends BOTH Deadline To Pay Income Taxes And Deadline To File Income Taxes By 90 Days

Today, the Treasury announced that it will also be pushing back the April 15th deadline to file 2019 income tax returns. As a result, taxpayers will not need to pay income taxes owed for 2019 and will not need to file 2019...more

Treasury Extends Deadline To Pay Income Taxes By 90 Days

Due to the Coronavirus Pandemic, the Treasury announced Tuesday that it will be pushing back the April 15th deadline to pay income taxes owed for 2019 by 90 days. In other words, until July 15, 2020, no taxpayer will be...more

Court Finds That Penalty For Late Filing Of Estate Tax Return Was Arbitrary And Capricious

Seasoned trusts and estates practitioners know certain truths, such as: Stuff happens. Some estate tax disputes should not be litigated, but they are anyway. Sometimes justice is done....more

10/22/2019  /  Estate Planning , Estate Tax , IRS , Tax Returns

IRS Is Sending “Educational” Letters To Virtual Currency Owners Advising Them To Report Crypto Transactions Properly And Pay Tax

In a news release on July 26, 2019, the IRS announced that it was sending letters to taxpayers with virtual currency transactions that potentially failed to report income and pay the resulting tax. See IR-2019-132. The...more

Proposed Regulations Clarify Rules For Qualified Opportunity Zone Planning

Last week, the IRS released proposed regulations regarding investing in Qualified Opportunity Funds (“QOFs”). The proposed regulations generally address three topics...more

IRS To Close Offshore Voluntary Disclosure Program This September

On March 13, 2018, the IRS announced that the Offshore Voluntary Disclosure Program (OVDP) will be closing on September 28, 2018. This program has been in place since 2009. In general, US persons, that is, citizens and...more

Failure To Plan and Inaction Lead To Increased New Jersey Estate Tax

The New Jersey Tax Court recently released its opinion in Estate of Ruth Oberg, NJ Tax Court, Docket No 000240 (October 24, 2017), upholding the Division of Taxation’s assessment of additional New Jersey estate tax. The case...more

11/27/2017  /  Estate Planning , Estate Tax , IRS , Valuation

IRS Withdraws Proposed Code §2704 Regulations On Lapsing Rights And Restrictions

The IRS has withdrawn the controversial proposed regulations under Code §2704 that would have significantly affected the use of discounts in US estate planning. Code §2704 provides that certain “applicable restrictions” on...more

Tax Court Holds That Foreign Corporation’s Sale Of A Partnership Interest Not Taxable In US

The US Tax Court recently held that a foreign corporation is not subject to US income tax on the sale of a partnership interest where the partnership conducts a US business. In so holding, the Tax Court rejected a 26 year...more

IRS Issues Proposed Regulations Under Code §2704 Impacting Gift and Estate Taxes

The IRS has at last issued long-anticipated proposed regulations under Code §2704. We perceive the proposed regulations as an attempt by the IRS to curtail the use of discounts – such as minority interest and lack of...more

Family Limited Partnerships: Are Discounts Disappearing?

“Family limited partnerships” – that is, family investment entities usually structured as LLCs or limited partnerships – have been a popular estate planning technique for years. Generally speaking, a client can transfer...more

Significant Revisions to the IRS Offshore Voluntary Disclosure Program

The existing OVDP has been in place since March 2009. The program allows a taxpayer to voluntarily come into compliance with US tax reporting obligations and pay a reduced civil penalty rather than facing either greater...more

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