The New Jersey Tax Amnesty Program applies to state tax liabilities for tax returns due on or after February 1, 2009 and prior to September 1, 2017. The program provides incentives for taxpayers who come forward and pay...more
The New Jersey Appellate Division recently issued its opinion in Estate of Van Riper v. Dir., Div. of Taxation, No. A-3024-16T4 (N.J. Super. Ct. App. Div. Oct. 3, 2018), upholding the Tax Court’s finding that the full fair...more
Last week, the IRS released proposed regulations regarding investing in Qualified Opportunity Funds (“QOFs”). The proposed regulations generally address three topics...more
10/25/2018
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Section 1400Z-2(a) of the Internal Revenue Code of 1986 (the “Code”), enacted as part of the 2017 federal Tax Cuts and Jobs Act is designated to spark long-term capital investment into low-income and urban communities, now...more
On October 19, 2018, the IRS released Revenue Ruling 2018-29, an eagerly awaited ruling addressing real estate investment in Qualified Opportunity Zones (“QOZs”). In brief, the Revenue Ruling holds that, for purposes of...more
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
The recently enacted 2017 tax act (originally called the Tax Cuts and Jobs Act – “Tax Reform Act”) contains sweeping changes to US international tax rules that will affect international businesses and cross border...more
The recently enacted 2017 Tax Act (originally called the Tax Cuts and Jobs Act – “Tax Reform”) made major changes to the US tax system. Because C corporations (“C corps”) are now taxed at a flat 21% federal income tax rate,...more
New Jersey recently enacted the Uniform Fiduciary Access to Digital Assets Act (the “Act”). In general, the Act provides executors, trustees, guardians, and power of attorney holders (“fiduciaries”) with the ability to access...more
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
The IRS has withdrawn the controversial proposed regulations under Code §2704 that would have significantly affected the use of discounts in US estate planning.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
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
On October 14, 2016, Governor Christie signed into law a transportation funding bill that also included the repeal of the New Jersey Estate Tax. Here is what you need to know: -
The New Jersey Estate Tax repeal will be...more
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
Prince was not the first famous person to die without a Will. Others who died intestate include: Abraham Lincoln, Ulysses S. Grant, Howard Hughes, Martin Luther King, Jr., Sonny Bono and Pablo Picasso. Dying intestate is...more
The loss of a loved one is a traumatic event and it can be among the most challenging of times to make important financial decisions. Proactive planning with an attorney and financial planner can significantly lessen the...more
“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
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
Estate tax exemption increase. Effective April 1, 2014, the New York State estate tax exemption increased to $2,062,500 for New York residents dying between April 1, 2014 and April 1, 2015 and will increase to $3,125,000 on...more
There have been important new developments for New York taxpayers over the past two months, some of which may require your immediate attention. ...more
Among other things, the Patient Protection and Affordable Care Act (the “Act”), commonly referred to as Obamacare, requires “large employers” to provide qualified health coverage for all of their full-time employees, or pay...more
Congress took the fiscal cliff negotiations over the brink but was finally able to reach a deal resulting in the American Taxpayer Relief Act of 2012 (“2012 Act”). The 2012 Act makes the estate and gift tax laws “permanent,”...more