It appears that many of the country’s colleges and universities believe they have not already contributed enough to the decline of American education and to the erosion of our society, generally.
These institutions of...more
11/9/2023
/ Activist ,
Annuities ,
Bad Actors ,
Business Income ,
Colleges ,
Dividends ,
Donors ,
Endowment Funds ,
Executive Compensation ,
Exempt Organizations ,
Federal Funding ,
Hate Speech ,
Income Taxes ,
Internal Revenue Code (IRC) ,
IRS ,
Non-Taxable Income ,
Operational Requirements ,
Public Charities ,
Public Policy ,
Rent ,
Royalties ,
Student Loans ,
Students ,
Tax Benefits ,
Tax Deductions ,
Tax Exemptions ,
Tuition ,
Universities
For many weeks, we’ve been hearing about the IRS’s plans to use the funding provided under the Inflation Reduction Act[i] to increase and expand its compliance and enforcement efforts with respect to the wealthy, high-income...more
10/27/2023
/ Affordable Care Act ,
Charitable Donations ,
Charitable Organizations ,
Excise Tax ,
Hospitals ,
Income Taxes ,
Inflation Reduction Act (IRA) ,
IRS ,
Medicaid ,
Reporting Requirements ,
Tax Deductions ,
Tax Exemptions
Many of you, perhaps most, may have read about a case that will be heard by the U.S. Supreme Court during its current term. The case, Moore v. United States, comes out of the Ninth Circuit Court of Appeals. The Supreme Court...more
10/13/2023
/ Amicus Briefs ,
Apportionment ,
Certiorari ,
Controlled Foreign Corporations ,
Duties ,
Equitable Distribution ,
Foreign Corporations ,
Foreign Investment ,
Foreign Partner ,
Income Taxes ,
Internal Revenue Code (IRC) ,
Net Investment Income ,
Pass-Through Entities ,
Reinvestment Funds ,
SCOTUS ,
Shareholders ,
Sixteenth Amendment ,
Subpart F ,
Tax Cuts and Jobs Act ,
Taxation ,
Ways and Means Committee
Approaching Year End-
Which holiday do you dread the most? For me, it has always been, and likely will always be, Labor Day. Of course, with each passing year, anything that I describe as “always” is less meaningful than...more
9/7/2023
/ Acquisitions ,
CFC ,
Controlled Foreign Corporations ,
Equity ,
FICA Taxes ,
Grantee ,
Income Taxes ,
Internal Revenue Code (IRC) ,
Medicare ,
Qualified Restricted Stock Units (RSUs) ,
Remuneration ,
Selling a Business ,
Social Security ,
Stocks ,
Taxable Income ,
Taxation ,
Vesting ,
Wages ,
Withholding Tax
Do you feel as challenged as I do when someone asks you to explain the term “Bidenomics”? I know that it is predicated upon the imposition of higher taxes on businesses and their owners, which have not yet materialized....more
8/17/2023
/ Business Ownership ,
Buyers ,
Cancellation of Debt (COD) ,
Capital Gains ,
China ,
Debt ,
Fair Market Value ,
Federal Budget ,
Federal Taxes ,
Income Taxes ,
Insolvency ,
IRS ,
Limited Liability Company (LLC) ,
Recessions ,
S-Corporation ,
Startups ,
Tax Court ,
Third-Party
It’s Complicated-
The Code includes a number of complex rules that are aimed at those overseas business and investment activities of U.S. taxpayers that Congress has determined may result in the improper deferral or...more
7/11/2023
/ CARES Act ,
Controlled Foreign Corporations ,
Foreign Corporations ,
Foreign Earned Income ,
Foreign Investment ,
Foreign Ownership ,
Foreign Tax ,
Income Taxes ,
Internal Revenue Code (IRC) ,
IRS ,
Parent Corporation ,
Senate Finance Committee ,
Stock Ownership ,
Subpart F ,
Tax Cuts and Jobs Act ,
Tax Deferral
The Supremes-
The Constitution has figured prominently in the news of late. In the days preceding the initial discussions among members of the Administration and the Congressional leadership regarding the debt ceiling,...more
5/24/2023
/ Debt Ceiling ,
Debt Collection ,
Federal Budget ,
Financial Records ,
Income Taxes ,
Internal Revenue Code (IRC) ,
Investigations ,
IRS ,
Notice Requirements ,
SCOTUS ,
Summons ,
Tax Liability ,
Third-Party
Hasta La Vista N.Y.-
Wealthy individuals continue to leave New York for tax friendlier jurisdictions.
Be Prepared-
Some of these taxpayers take a very methodical approach toward planning for their departure. They...more
5/18/2023
/ Administrative Law Judge (ALJ) ,
Audits ,
Capital Gains ,
Documentation ,
Domicile ,
Exit Tax ,
Income Taxes ,
Limited Liability Company (LLC) ,
Membership Interest ,
New York ,
Non-Resident Income Taxes ,
Purchase and Sale Agreements ,
Relocation ,
State Taxes ,
Tax Court ,
Taxation
At war with Russia in eastern Europe, a nascent competing world order, mass shootings and bank failures at home, questionable audit practices by the Big 4 . . . everywhere, debt ceilings and the risk of default, inflation,...more
5/12/2023
/ Capital Contributions ,
Capital Gains ,
Capital Investments ,
Fair Market Value ,
Future Profits ,
Income Taxes ,
Internal Revenue Code (IRC) ,
Investors ,
IRS ,
Limited Liability Company (LLC) ,
Liquidation ,
Partnership Interests ,
Partnerships ,
Profits Interests ,
Safe Harbors ,
Tax Court ,
Term Sheets
Many years ago, New York revised its personal income tax law to achieve close conformity with the Federal system of income taxation. The stated purpose for the revision was to simplify tax return preparation, improve...more
3/27/2023
/ Adjusted Gross Income ,
Audits ,
Documentation ,
Income Taxes ,
IRS ,
New York ,
Real Estate Professionals ,
Rental Property ,
State Taxes ,
Tax Appeals ,
Tax Deductions ,
Taxable Income ,
Taxation
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
History is replete with examples of leaders who chose to battle, or who were forced into defending against, enemies on two fronts. Rarely did it end well for the combatant that occupied the middle ground.
In a sense, New...more
3/1/2023
/ Amicus Briefs ,
Bona Fide Relationship Test ,
Connecticut ,
Coronavirus/COVID-19 ,
Double Taxation ,
Income Taxes ,
Local Revenues ,
New Jersey ,
New York ,
Non-Resident Income Taxes ,
Non-Residents ,
Out-of-State Employees ,
Remote Working ,
State Taxes ,
Tax Policy ,
Tax Revenues ,
Telecommuting
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
Every now and then, some well-meaning colleague will ask how I spend my free time. I usually pause before responding – to gather my thoughts – which prompts them to restate their question with what they believe is greater...more
1/13/2023
/ Business Income ,
Business Profits ,
Income Taxes ,
Investment ,
IRS ,
Loans ,
Profits ,
Tax Court ,
Tax Deductions ,
Tax Losses ,
Tax Planning ,
Taxable Income
I am guessing that, later this week, many if not most of us will celebrate our uniquely American holiday, Thanksgiving Day. Hopefully, we will be fortunate enough to spend the day and share a meal with family and friends....more
11/23/2022
/ Business Licenses ,
Gambling ,
Gaming Revenues ,
Holidays ,
Income Taxes ,
Marijuana ,
Marijuana Related Businesses ,
New York ,
Recreational Use ,
Retailers ,
Tax Revenues ,
Thanksgiving
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
Where is the Economy Heading?
According to the data released Friday by the Department of Labor, the U.S. economy added approximately 528,000 jobs in July, reducing the unemployment rate to 3.5 percent. Although this...more
8/9/2022
/ Administrative Law Judge (ALJ) ,
Business Taxes ,
Closely Held Businesses ,
Department of Labor (DOL) ,
Federal Reserve ,
Foreign Markets ,
Income Taxes ,
IRS ,
New York ,
Price Inflation ,
Tax Appeals ,
Tax Liability ,
Tax Tribunal ,
Unemployment ,
Wages ,
Withholding Tax
“Summertime and the Living” Isn’t Easy-
Summer in the New York Metro Area can be challenging. Some would say it sucks. It gets really hot. When it rains, it pours – no spritz here. The humidity is oppressive. Ironically, a...more
7/20/2022
/ Administrative Law Judge (ALJ) ,
Audits ,
Business Licenses ,
Business Ownership ,
Cannabis Products ,
Cannabis-Related Businesses (CRBs) ,
Cost-of-Living Adjustment (COLA) ,
Domicile ,
Financial Statements ,
Florida ,
Homestead Exemption ,
Income Taxes ,
Information Document Requests ,
New York ,
Non-Residents ,
Online Gaming ,
Price Inflation ,
S-Corporation ,
Sports Betting ,
State Budgets ,
State Taxes ,
Stock Markets ,
Tax Increases ,
Tax Revenues
Deal Costs, Generally-
Every purchase and sale of a business, whether from the perspective of the seller or the buyer, is about economics, and few items will impact the economics of the transaction more certainly or...more
7/12/2022
/ Capital Assets ,
Capital Losses ,
CCA ,
Income Taxes ,
IRS ,
Limited Liability Company (LLC) ,
Selling a Business ,
Target Company ,
Tax Benefits ,
Tax Deductions ,
Termination Fees
Escape from New York-
According to data released by the IRS earlier this year, the pandemic triggered a “wealth migration” that saw high-tax states like New York lose high-income earners to low-tax jurisdictions such as...more
7/6/2022
/ Administrative Law Judge (ALJ) ,
Appellate Courts ,
CPLR ,
Income Taxes ,
IRS ,
New York ,
Non-Permanent Residents ,
Non-Residents ,
Price Inflation ,
Remote Working ,
Residency Status ,
Resident Non-Domiciled (RND) ,
Stabilization Issues ,
State Taxes ,
Tax Appeals ,
Tax Returns ,
Tax Revenues ,
Tax Tribunal ,
Vacation Homes
Sale of the Business-
Imagine Client has just received an attractive, all cash offer for the sale of their business; there is no financing contingency. The buyer has proposed a cash-free and debt-free deal....more
5/17/2022
/ Balloon Payments ,
Borrowers ,
Cash Transactions ,
Debt ,
Fair Market Value ,
Income Taxes ,
Installment Agreements ,
Lenders ,
Promissory Notes ,
Secured Debt ,
Selling a Business ,
Tax Deferral ,
Tax Liability ,
Tax Returns ,
Trusts
Limited Liability?
Many individual taxpayers who invest in a closely held business, including one organized as a corporation, fail to appreciate there are circumstances in which they may be held personally liable by a...more
5/10/2022
/ Audits ,
Closely Held Businesses ,
Corporate Taxes ,
Duty to Act ,
Financial Transaction Tax ,
Income Taxes ,
Information Document Requests ,
New York ,
Personal Liability ,
Sales Tax ,
Shareholders ,
Tax Appeals
“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
Please join us as Louis Vlahos and Bernadette Kasnicki provide a refresher on preparing Form 990, the tax return for tax-exempt organizations. We will review…...more