End of Year Tax Planning: Tips for Healthcare Professionals and Practices
4 Key Takeaways | Mid-Year Tax Update
THE ACCIDENTAL ENTREPRENEUR PART IV
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On January 21, 2025, New York Governor Hochul released her Fiscal Year 2026 Executive Budget and accompanying legislation (the Budget Bill). The Budget Bill includes a middle-class tax cut, a temporary personal income tax...more
A changing tax landscape is on the horizon for the new year. Many of the provisions of the 2017 Tax Cuts and Jobs Act (“TCJA”) are scheduled to expire at the end of the year. President-elect Trump has also proposed a variety...more
On 10/22/24, the IRS announced that is has officially commenced operations of the newly established pass-through field operations unit within its Large Business and International (LB&I) division, which was announced last...more
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
The IRS’s simmering concern with pass-through entities is heating up, with IRA funds earmarked for increased personnel, AI, and other resources for partnership audits. ...more
There’s a hidden tax horror behind pass-through entities, cancellation of debt, and even prizes, winning, and awards: “phantom income.” It even sounds scary, right? And when it comes to one’s tax liability, it can be...more
After much anticipation, the IRS has finally announced a strategic operating plan to spend the nearly $80 billion in funds that it was allocated through the Inflation Reduction Act. Since this bill was signed, the new IRS...more
Only months after the U.S. Tax Court and the 6th Circuit Court of Appeals ruled that the IRS failed to adhere to the Administrative Procedures Act when it promulgated Notice 2017-10 and designated most Syndicated Conservation...more
I recently encountered an interesting situation in which someone suggested that a grantor trust be decanted into a non-grantor trust before the end of the taxable year. The reason? To avoid the special interest charge that...more
In IRS Notice 2020-75, the IRS invited the states to circumvent the $10,000 limit on the deduction of state taxes by individuals, trusts, and estates for purposes of calculating federal income tax by permitting the states to...more
Syndicated Conservation Easements - In an IRS news release of January 17, 2022, the IRS’s Office of Chief Counsel announced that plans to hire up to 200 additional attorneys “to help the agency combat syndicated...more
On January 25, 2022, the Internal Revenue Service (the “IRS”) and the Department of the Treasury (“Treasury”) released regulations (the “Final Regulations”) finalizing provisions in prior proposed regulations which generally...more
Timing- I had planned to post this piece during the third week of December, a day or so after the exchange between Senator Manchin and the White House sealed the fate of the Build Back Better plan, at least in its current...more
Last fall, the IRS announced, with respect to pass-through entities (LLCs or other entities taxed as partnerships or S corporations), that, if state law allows or requires the entity itself to pay state and local taxes (which...more
On October 27, 2021, Senate Finance Committee Chair Ron Wyden (D-Ore.) released draft legislation that would, if enacted, tax the roughly 700 wealthiest Americans on a modified mark-to-market basis by requiring them to pay...more
One of the most controversial individual income tax changes enacted under the Tax Cuts and Jobs Act of 2017 is the $10,000 cap on the deduction for state and local income and property taxes (“SALT”) for federal income tax...more
While business owners wait to see whether Congress raises the U.S. long-term capital gains rate from 20 percent to 25 percent and enacts relief from the limitations on the deductibility of state and local taxes (SALT),...more
Section 965 audits are on the rise. Taxpayers under section 965 transition tax audits often face significant potential liability exposure. The IRS previously announced an active “campaign” specifically targeting unpaid...more
The difference between the amount of tax owed by Taxpayers for a given year and the amount that is actually paid timely for that same year is known as the “Gross Tax Gap”. The IRS looks at this number as an estimate of the...more
One of the best-known features of bankruptcy law is the automatic stay, which prevents a variety of actions to collect debts and to take possession or control of anything considered “property of the estate.” However, one...more
The UK government has published a response to the consultation announced last year in relation to the possible introduction of a new tax advantaged regime for UK asset holding companies (AHC) used in the context of...more
New Jersey recently enacted the “Pass-Through Business Alternative Income Tax Act,” which allows pass-through businesses with at least one member liable for the New Jersey gross income tax to make an election to pay income...more
Congress enacted the new Section 199A 20% profit deduction for the owners of pass-through businesses, and which include Subchapter S corporations, LLCs, sole proprietorships, and even certain trusts. Section 199A is intended...more
This document discusses Notice 2018-26, the third IRS Notice providing guidance on the new mandatory repatriation tax under § 965. Most importantly, the Notice sets forth extensive anti-avoidance rules in respect of...more
Gov. Kay Ivey signed House Bill 384, into law last Wednesday, March 28, ending a debate that has lasted for almost a decade over the scope of the individual income tax credit for certain taxes paid to other states. ...more