New York’s personal income tax law, like that of other states, conforms with the federal system of income taxation. The reason typically given for such conformity is to simplify tax return preparation, improve compliance and...more
7/24/2025
/ Audits ,
Compliance ,
Income Taxes ,
Internal Revenue Code (IRC) ,
IRS ,
Like Kind Exchanges ,
Limited Liability Company (LLC) ,
New York ,
Partnerships ,
Real Estate Transactions ,
Section 1031 Exchange ,
State Taxes ,
Tax Liability ,
Tax Planning ,
Tax Returns ,
Taxation
The “One Big Beautiful Bill Act” (the “Act”) was signed into law last week, on July 4. As promised by the White House, the Act extends – i.e., purports to make “permanent” – many of the otherwise expiring provisions that were...more
7/14/2025
/ Business Taxes ,
Closely Held Businesses ,
Estate Tax ,
Federal Taxes ,
Gift Tax ,
Income Taxes ,
Internal Revenue Code (IRC) ,
IRS ,
New Legislation ,
One Big Beautiful Bill Act ,
Partnerships ,
Qualified Small Business Stock ,
Small Business ,
Tax Cuts and Jobs Act ,
Tax Deductions ,
Tax Legislation ,
Tax Planning ,
Tax Reform ,
Tax Returns
Late last year, the Office of the State Comptroller (the “OSC”) estimated that sales and use tax receipts would increase by 2.3% in the SFY 2024-2025. The OSC also projected that collections from sales and use taxes would...more
2/18/2025
/ Appeals ,
Audits ,
Business Entities ,
Compliance ,
Corporate Governance ,
Corporate Misconduct ,
Delinquency Status ,
New York ,
Noncompliance ,
Penalties ,
Personal Liability ,
Sales Tax ,
Shareholders ,
State and Local Government ,
State Taxes ,
Tax Liability ,
Tax Returns ,
Taxation
If you’ve worked with the owners of closely held businesses for even just a few years, you have realized they are only half joking when they complain about having the government as a partner. Consider how much federal, state,...more
1/28/2025
/ Business Entities ,
Business Ownership ,
Closely Held Businesses ,
Enforcement ,
Enforcement Actions ,
Income Taxes ,
Internal Revenue Code (IRC) ,
IRS ,
Limited Liability Company (LLC) ,
Partnerships ,
Tax Court ,
Tax Liability ,
Tax Planning ,
Tax Returns ,
Withholding Tax
Just a few weeks ago, many individual taxpayers, driven by what they viewed as the relatively imminent expiration of the enhanced federal transfer tax exemptions, sought advice on how to leverage their remaining exemption and...more
1/14/2025
/ Estate Planning ,
Estate Tax ,
Federal Taxes ,
Income Taxes ,
Internal Revenue Code (IRC) ,
IRS ,
Limited Liability Company (LLC) ,
Limited Partnerships ,
Partnerships ,
Tax Exemptions ,
Tax Liability ,
Tax Planning ,
Tax Returns ,
Trusts
During the weeks leading up to the Presidential election, the media carried stories about wealthy supporters from each Party who had announced their intention to leave the country if the other Party’s candidate became...more
11/22/2024
/ Business Ownership ,
Capital Gains ,
Citizenship ,
Domicile ,
Exit Strategies ,
Exit Tax ,
New York ,
Non-Resident Income Taxes ,
Presidential Elections ,
Residency Status ,
Selling a Business ,
State Taxes ,
Tax Appeals ,
Tax Returns
Earlier this year the IRS announced that, as part of its larger compliance efforts begun last fall under the Inflation Reduction Act, the agency’s stepped-up enforcement activity with respect to high wealth, high income...more
10/31/2024
/ Audits ,
Compliance ,
Debt Collection ,
Deficiency Notices ,
Documentation ,
Due Process ,
Inflation Reduction Act (IRA) ,
IRS ,
Overpayment ,
SCOTUS ,
Solicitor General ,
Statute of Limitations ,
Tax Appeals ,
Tax Court ,
Tax Debt ,
Tax Levy ,
Tax Liability ,
Tax Returns
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
8/20/2024
/ Board of Directors ,
CEOs ,
CFOs ,
Corporate Dissolution ,
Deficiency Notices ,
Embezzlement ,
IRS ,
K-1 ,
Misappropriation ,
S-Corporation ,
Settlement Agreements ,
Shareholder Distributions ,
Shareholders ,
State Courts ,
Stock Transfer ,
Tax Returns ,
Taxable Income ,
Whistleblowers
Over the years, I have observed there is only one thing that a taxpayer fears more than being notified by the IRS that their income tax return for a particular taxable year has been selected for audit, and that is being...more
4/24/2024
/ Audits ,
Court of Federal Claims ,
Debt Collection ,
Deficiency Notices ,
Filing Deadlines ,
Income Taxes ,
Internal Revenue Code (IRC) ,
IRS ,
Lack of Jurisdiction ,
Petition for Writ of Certiorari ,
Redeterminations ,
SCOTUS ,
Tax Court ,
Tax Penalties ,
Tax Returns
Imagine the IRS notifies Taxpayer that they have an outstanding tax liability with respect to Tax Year, and that the agency intends to levy on Taxpayer’s property to collect the allegedly unpaid tax. Taxpayer challenges the...more
4/19/2024
/ Income Taxes ,
Internal Revenue Code (IRC) ,
IRS ,
Overpayment ,
Popular ,
Spouses ,
Tax Appeals ,
Tax Court ,
Tax Debt ,
Tax Levy ,
Tax Liability ,
Tax Refunds ,
Tax Returns
As we approach the deadline for paying federal individual income taxes and, generally, for filing the returns on which such taxes are determined, some of you may be recalling how the Inflation Reduction Act of 2022...more
4/11/2024
/ Administrative Law Judge (ALJ) ,
Attendance ,
Compensation & Benefits ,
Federal Employees ,
Income Taxes ,
Inflation Reduction Act (IRA) ,
Internal Revenue Code (IRC) ,
IRS ,
Misleading Statements ,
Paid Time Off (PTO) ,
Performance Reviews ,
Privately Held Corporations ,
Sick Leave ,
Surveillance ,
Tax Returns ,
Termination ,
Treasury Inspector General for Tax Administration (TIGTA) ,
U.S. Treasury
Heads I Win, . . . -
When closely held corporations that are under common control engage in any intercompany transaction, it is prudent for the corporations and their shareholders to ensure that the transaction is being...more
2/2/2024
/ Business Losses ,
Business Taxes ,
Capital Contributions ,
CFOs ,
Closely Held Businesses ,
Creditors ,
Debt ,
Earnings Reports ,
Fund Distribution ,
Intent ,
Intercompany Transactions ,
Investment ,
IRS ,
Loan Repayment Issues ,
Loans ,
Tax Court ,
Tax Returns ,
Taxable Distributions
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
12/8/2023
/ Administrative Law Judge (ALJ) ,
Capital Gains ,
Carried Interest ,
Compensation ,
Conciliation ,
Dividends ,
Double Taxation ,
Investment Management ,
K-1 ,
Limited Liability Company (LLC) ,
New York ,
Non-Residents ,
Partnerships ,
Relocation ,
Resident Status ,
State Taxes ,
Tax Appeals ,
Tax Credits ,
Tax Rates ,
Tax Returns ,
Taxable Income ,
Tribunals
Death of a Parent-
In the context of a family-owned business, it is often the case that the matriarch or patriarch of the family is also the chief executive of the business. They may have founded the business, or they may...more
8/11/2023
/ Closely Held Businesses ,
Estate Planning ,
Estate Tax ,
Family Businesses ,
Heirs ,
Insolvency ,
Internal Revenue Code (IRC) ,
IRS ,
Spouses ,
Surviving Spouse ,
Tax Court ,
Tax Liability ,
Tax Liens ,
Tax Returns ,
Transfer Taxes ,
Trusts
What Was Intended?
Transactions between commonly controlled, closely held businesses are often conducted in an informal manner. This is unfortunate because, in the absence of documentation, it is sometimes difficult to...more
7/20/2023
/ Bad Debt ,
Capital Assets ,
Capital Contributions ,
Closely Held Businesses ,
Creditors ,
Debt ,
Debtor-Creditor ,
Deductions ,
Equitable Contribution ,
Equity ,
Fair Market Value ,
Fund Transfers ,
Investment ,
IRS ,
Loans ,
Ownership Interest ,
Real Estate Development ,
S-Corporation ,
Secured Debt ,
Tax Court ,
Tax Liability ,
Tax Returns
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
5/3/2023
/ Articles of Incorporation ,
Bonuses ,
Burden of Proof ,
Capital Gains ,
Change in Control ,
Charitable Donations ,
Due Diligence ,
Gift Tax ,
IRS ,
Letters of Intent ,
Private Equity ,
Purchase Agreement ,
Registered Investment Advisors ,
Selling a Business ,
Shareholder Distributions ,
Stock Purchase Agreement ,
Tax Court ,
Tax Returns
The Mid-Terms-
With 50 seats in the Senate, the Dems still control that Chamber. A win in the Georgia runoff, however, may lessen the burden for Majority Leader Schumer by, perhaps, neutralizing the significance of a certain...more
11/17/2022
/ Business Ownership ,
Business Taxes ,
Domicile ,
IRS ,
Jurisdiction ,
Partnership Interests ,
Political Candidates ,
Political Parties ,
Primary Residence ,
State Elections ,
State Taxes ,
Tax Returns
When is a loan not a loan? When it’s something else – for example, equity.
This is one of those pesky facts and circumstances issues that plague courts, taxpayers, and tax advisers to no end.
Debt- On one end of the...more
9/9/2022
/ Borrowers ,
Debt ,
Equity ,
Fixed-Rate Loans ,
Interest Rates ,
IRS ,
Lenders ,
Limited Liability Company (LLC) ,
Loan Documentation ,
Loans ,
Partnerships ,
Preferred Shares ,
Tax Court ,
Tax Returns ,
Value Appreciation
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
The Housing Market-
During the first quarter of 2022, the housing market accounted for 16.7 percent of gross domestic product (“GDP”). This figure represents a return to historic norms following the substantial reduction...more
6/15/2022
/ Affordable Housing ,
Capital Gains ,
GDP ,
Great Recession ,
Housing Market ,
Internal Revenue Code (IRC) ,
Inventory ,
Limited Liability Company (LLC) ,
Mortgages ,
Real Estate Brokers ,
Real Estate Development ,
Real Estate Investments ,
Real Estate Market ,
Tax Court ,
Tax Returns
State Finances-
Much has been written over the last few weeks about the unprecedented financial cushion that many states have accumulated thanks to federal support prompted by the pandemic and larger-than-expected tax...more
5/24/2022
/ Adjusted Gross Income ,
Administrative Law Judge (ALJ) ,
Audits ,
Federal Aid ,
IRS ,
Limited Liability Company (LLC) ,
New York ,
State Budgets ,
State Taxes ,
Tax Appeals ,
Tax Liability ,
Tax Returns ,
Tax Revenues ,
Taxable Income
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
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
Double Tax-
The shareholders of C corporations have long sought legitimate operational and transactional structures by which they may reduce the double tax hit that is realized when such a corporation distributes its...more
3/11/2022
/ Audits ,
Burden of Proof ,
C-Corporation ,
Closely Held Businesses ,
Corporate Bonuses ,
Corporate Net Income ,
Disguised Sales ,
Dividends ,
Income Taxes ,
IRS ,
Job Duties ,
Midsize and Large Business Loans ,
Multi-Factor Test ,
Purchase Price ,
Reasonable Compensation ,
Salary/Wage History ,
Sale of Assets ,
Shareholders ,
Tax Liability ,
Tax Returns
Mention the “tax season” and most folks think of the weeks leading up to the April 15 deadline for filing one’s federal individual income tax return and paying the associated income tax. Truth be told, given the number of...more