KNOCK YOURSELF OUT - RESUSCITATING TAXPAYERS WITH BUYER'S REMORSE!
You may recall that earlier this year the IRS launched an initiative to pursue 125,000 “high-income, high-wealth” taxpayers who have not filed taxes since 2017. These were cases where the IRS received third party information...more
As far back as I can remember, the end of August has always elicited a sense of dread comparable to what many schoolchildren, and a fair number of adults, experience every Sunday afternoon. In retrospect, I cannot say that...more
El 6/28/24, el Tesoro de los EE. UU. y el IRS emitieron regulaciones finales con una fecha de vigencia del 9/9/24 que requieren que los brokers de custodia reporten las ventas e intercambios de activos digitales a partir del...more
On 6/28/24, the U.S. Treasury and the IRS issued final regulations with an effective date of 9/9/24 requiring custodial brokers to report sales and exchanges of digital assets beginning in calendar year 2025. Meaning,...more
Tips are in the news lately. It seems like political strategists on both sides of the aisle have concluded that excluding tips from taxable income is good for votes. One has to wonder if this political promise will go the way...more
The commercial real estate market is in the process of adjusting to lower property valuations. Much recent focus has been on office buildings, and the fallout from enduring reductions in occupancy associated with remote and...more
If given their druthers, most transactional corporate attorneys would prefer to spend their day practicing “happy law,” by which they typically mean transactions that involve capital formation, mergers and acquisitions, joint...more
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
This article is the second in our series on equity-based compensation intended to assist employers with answering a common question: What type of equity compensation award is best for our company and our employees? ...more
How does the IRS define willfulness in unreported or under-reported offshore income? What actions help determine whether a U.S. taxpayer's actions amount to "willful or non-willful" conduct? Why should U.S. taxpayers be...more
Each month, we publish a roundup of the most important SEC enforcement developments for busy in-house lawyers and compliance professionals. This month, we examine: •The permanent suspension of an audit firm and its owner for...more
Understanding market trends and effective planning strategies can yield improved financial results for start-ups and growth companies. Starting your start-up. What type of entity you form impacts your taxes, which hits your...more
On April 5, 2024, the New Jersey Division of Taxation issued guidance discussing New Jersey’s adoption of the federal centralized partnership audit regime enacted as part of the federal Bipartisan Budget Act of 2015, P.L....more
Many believe that college athletics is in the process of transitioning to a structure in which at least some student-athletes are considered “employees.” The NCAA and its member institutions are facing a variety of antitrust,...more
What are the tax accounting rules for hedges? Whether or not a qualified tax hedge is properly identified, it must be tax accounted for under a method that clearly reflects income. The timing of gains and losses on hedges...more
We are entering a strange new world where there are evolving questions about whether assets and rights are federally regulated or state managed. Some of this is traceable to Dobbs v. Jackson Women’s Health, the case that...more
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
The Commonwealth of Pennsylvania changed its tax treatment of assistance that employers provide for dependent care services – including dependent care flexible spending accounts. Retroactive to January 1, 2023, Pennsylvania...more
The Tax Court’s decision in YA Global Investments LP v. Commissioner in November sends a warning to the offshore banking, finance and equity investment industries: an offshore entity is engaged in U.S. trade or business when...more
La planificación fiscal le aplica a todos. El 1/22/24, el IRS le recordó a todos los contribuyentes que comenzaran a prepararse para presentar su declaración de impuestos federales sobre la renta. Planificar con anticipación...more
Tax planning applies to everyone. On 1/22/24, IRS reminded all taxpayers to start getting ready to file their federal income tax return. Planning ahead can help taxpayers file an accurate return and avoid delays that can slow...more
Medicaid is a joint federal and state program that provides health coverage to millions of Americans. Federal law requires states to comply with certain minimum requirements, but New York is considered a maximum state in that...more
The Office of the New York State Comptroller just released a new report that examines taxpayer migration trends during the pandemic. The report, which builds on an earlier analysis of pre-pandemic taxpayer migration trends,...more
Uncertain Future- The Congressional Budget Office (“CBO”) recently released some data for the federal government’s 2023 fiscal year. According to the CBO, the federal budget deficit for the year was $1.7 trillion, or...more
On September 12, the Arizona Supreme Court declined to take review in ADP, LLC v. Ariz. Dep’t of Revenue, No. CV-23-0036-PR., which lets stand the Arizona Court of Appeals opinion in the same case. 254 Ariz. 417, No. 1 CA-TX...more