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Some Observations On Recent Conversions of Partnerships to “C” Corporations

Decisions- It is often the case that the optimal form of legal entity through which a business should operate, at least for income tax purposes, will depend in part upon the stage of its life cycle in which the business...more

Corporate-Owned Life Insurance, a Redemption, and The Value of a Decedent’s Stock

Estate Tax – It’s a Killer- One of the reasons often given for eliminating the estate tax is the substantial economic burden it places upon the estate of a deceased business owner and upon the business itself. Specifically,...more

Tax Planning for Business Owners Who Shortchange Themselves

Something’s Wrong- Of late, a not insignificant number of the business owners with whom I’ve been working have raised some concern over whether they are financially prepared for the next stage of their lives. ...more

Supreme Court Upholds IRS Collections Summons Without Notice

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

Can You Be Sure You’ve Left New York Before The Sale of Your Business? Will It Matter?

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

Indirectly Held Profits Interests and Rev. Proc. 93-27

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

Selling Your Business? Careful of Pre-Sale Contributions of Stock to Charity

Charitable Giving Update- According to a recent report on charitable giving, the number of donors at every level of giving dropped during the first three quarters of 2022. The number of new donors was down by over 19...more

Sotheby’s N.Y. Sales Tax “Woes” Revisited

A Dirty Business? The art world is replete with tales of whodunits, forgeries, thefts, money laundering, looting of antiquities, murders, ancient curses, etc. You might say it’s a perfect environment for the more...more

Hospital As Educational Organization? The Mayo Clinic’s UBIT Refund Claim

Like Peas in a Pod? What do private, not-for-profit colleges and hospitals have in common? There are quite a few items that come immediately to mind: •They may qualify for exemption from federal income tax. •Tax-exempt...more

The Federal Attack on Grantor Trusts: The Demise of Basis Step-Up at Death?

On March 20, 2023, Senators Warren, Sanders, Van Hollen, and Whitehouse addressed a letter to Treasury Secretary Yellen in which they urged Yellen “to use [her] existing authority to limit the ultra-wealthy’s abuse of trusts...more

IRS Wraps Up Its 2023 Dirty Dozen List

Every year, the IRS compiles a list of common scams that taxpayers may encounter – its so-called “Dirty Dozen.” Today, the Service wrapped up the annual Dirty Dozen list of tax scams for 2023 with a reminder for taxpayers,...more

New York Examines Federal Income Tax Issues –Conformity and . . . Disclosure?

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

Sale of Partnership Interests . . . In the Ordinary Course of Business?

What Is It? Where one stands on an issue of tax law may depend upon context and perspective, including the facts and circumstances one finds relevant, and whom one is counseling or representing. Tax advisers often find...more

The President’s 2024 Federal Budget: “Reforming” the Taxation of High-Income Taxpayers

The Budget and Accounting Act of 1921 established the requirement that the President submit a budget to Congress for the upcoming fiscal year. Among other things, the proposed federal budget affords the President an...more

The Closely Held Business and The Tax Gap

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

New York’s Convenience of the Employer Rule – New Jersey and Connecticut Respond

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

Foreign Individuals Holding U.S. Real Property, or Left Holding the Bag?

There have been some interesting developments of late with respect to the ownership of real property in parts of the English-speaking world. For example, Canada has imposed a temporary ban on the purchase of such property by...more

George Washington on Debt and Taxes

On Monday, February 20, we celebrate the birthday of George Washington. We honor this extraordinary individual who, in 1775, was unanimously selected by the otherwise fractious Continental Congress as the commander in chief...more

Applying FIRPTA to Short Sales

State of the “Union” Did you watch the President’s state of the union address the other night? Was it as you expected? Were you hoping for something more? Were you disappointed? Did you find it informative? Maybe...more

You “Placed Your Trust” In New York? You May Be Sorry You Did

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

Will New York Increase Taxes On Investment Income?

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

Tax Losses Realized During the Crypto Winter

Debacle- Understanding the etymology of a word often enables us to better understand or appreciate its use in contemporary speech. For example, the word “crypto” is derived from the Greek word “krypto,” which describes...more

Generating Tax Losses as a Hobby

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

Trump’s Returns and Congress – Lessons, Next Steps?

Last Friday, December 30, 2022, during the final hours of the 117th Session of Congress, the House Ways and Means Committee – through which all tax legislation passes – released redacted versions of six years of Mr. Trump’s...more

New York’s “No-Longer-a-Sin” Taxes – Effective? Progressive? Neither?

Lately I’ve been thinking about the many ways by which members of the public transfer funds to government and the many reasons for which such transfers are made. After all, we’re still in the “season of giving.”...more

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