News & Analysis as of

Closely Held Businesses Tax Liability

Barnea Jaffa Lande & Co.

Israeli tax reform in relation to "closely held companies"

At the end of 2024, the Knesset enacted significant legislative updates within the framework of the Arrangements Law that completely revamp how “closely held companies” are taxed in Israel. Section 76 of the Income Tax...more

Rivkin Radler LLP

Not Aware of Your Business Partner’s Tax Situation? Maybe You Should Be

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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

Miles & Stockbridge P.C.

Supreme Court Case Adversely Impacts Parties to Buy-Sell Arrangements

In a unanimous decision, the Supreme Court of the United States recently determined in Connelly v. U.S. that the value of a life insurance policy must be included in the fair market value of a closely held business for...more

Mayer Brown

Closely-Held Corporation Buy-Sell Arrangements Upended by Supreme Court in Estate of Connelly

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The Supreme Court has just weighed in on how gift and estate taxes apply with respect to non-cash gifts in Estate of Connelly v. United States. The Court’s opinion closely follows the economics of such arrangements, but...more

Womble Bond Dickinson

Supreme Court Decision in Connelly v. United States

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On June 6, 2024, the United States Supreme Court issued its decision in in Connelly, As Executor of the Estate of Connelly v. United States, (602 US ________). The decision involves the application of the federal estate tax...more

Rivkin Radler LLP

Shareholder-Transferee Liability for a Corporation’s Income Tax

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Would you be surprised to learn that most shareholders of closely held corporations, and especially those with minority or merely passive interests, believe they cannot be held responsible for the tax obligations of their...more

Rivkin Radler LLP

Disclaiming to Save Taxes

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It’s not enough for the founder of a closely held business to have successfully established the business. The business has to grow, not only to increase profits, but also to make it more competitive and to diversify its...more

Rivkin Radler LLP

Transferee Liability for Estate Tax: The Downside of Being a Beneficiary

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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

Rivkin Radler LLP

Debt or Equity? The Never-Ending Question For Closely Held Businesses

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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

Rivkin Radler LLP

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

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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

Rivkin Radler LLP

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

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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

Rivkin Radler LLP

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

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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

Rivkin Radler LLP

Transacting With One’s Business – Keep It Arm’s Length

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Don’t Be Unreasonable- Much has been written of late regarding the payment by a business of various personal expenses incurred by its owner or certain key employees. The payment of an owner’s personal expenses appears to...more

Rivkin Radler LLP

Private Foundations, Closely Held Businesses, And Distribution Requirements

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“Show Me the Money”- Much has been written in recent months about how well the investment portfolios of private foundations have performed over the last several years. For example, a study conducted by the Council on...more

Rivkin Radler LLP

New York to Taxpayer: “Forget What the Feds Said, You’re a ‘Responsible Person"

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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

Rivkin Radler LLP

Reasonable Compensation Meets The Principal Shareholder of a C Corp

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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

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Me, Myself, and I: Tax Liabilities and Dealing with One’s Own Business

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“It’s My Business”- The owner of a closely held business will often find it difficult to distinguish the business from their own person. That is certainly true for a sole proprietorship. In many cases, unfortunately, the...more

Rivkin Radler LLP

New York’s Pass-Through Entity Tax, F Reorgs, and the Sale of An Electing S Corp

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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

Rivkin Radler LLP

Cash In Hand, Tax Deferral, Monetized Installment Sales: No, You Can’t Have It All

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Ask the owner of a closely held business to describe their most recently recurring nightmare and you are likely to get an earful regarding the prospect of an increased federal income tax on their profits, an increased federal...more

Rivkin Radler LLP

The President’s Recent Tax Proposals: What Do They Mean For Business Owners?

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A Night to Remember? Did you listen to the President’s speech last Wednesday? He addressed a joint session of Congress to pitch the Administration’s $1.8 trillion American Families Plan. Due to COVID-related...more

Jones Day

IRS to Begin Examination of Hundreds of High-Wealth Individuals Starting July 15

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The Internal Revenue Service ("IRS") announced that as soon as it reopens its collection and examination functions on July 15, it will immediately begin the examination of hundreds of high-income individuals and private...more

Goulston & Storrs PC

T&E Litigation Newsletter - September 2014 #1

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In United States of America v. Estate of Robert Reitano, Civil Action No. 12-11944-RWZ, 2014 U.S. Dist. LEXIS 123200 (D. Mass. Sept. 4, 2014), the federal district court issued a warning shot to estate fiduciaries who fail to...more

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