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A parent will sometimes transfer money to a child to enable the child to make an investment that the child could not otherwise make on their own. For example, the child may have identified an attractive business opportunity...more
Taxpayers seeking to contest real property tax values established by assessing jurisdictions across the country often have a short window of opportunity to contest their new valuation. Property taxes are frequently the...more
Annual Survey of Income and Expenses – ASIE-2024 As of February 1st, 2025, pursuant to the Nassau County Administrative Code, Section 6-30, the Nassau County Department of Assessment (“the Assessor”) is requiring the...more
Art and collectibles, while beautiful and culturally significant, can pose significant estate planning challenges. At the time of death, these assets are subject to estate taxes based on their fair market value. Without...more
When it comes to estate taxes, the Internal Revenue Service (IRS) expects all tangible personal property to be properly reported on Schedule F of Form 706. This includes any valuable assets such as art collections, antiques,...more
It’s the holiday season! For many that means spending time with family and friends. A new year rings in, and then…like clockwork, the Nassau County Department of Assessment publishes the tentative assessment roll as of...more
Earlier this month, the Internal Revenue Service (“IRS”) released Form 15620, which is an approved IRS form for making Internal Revenue Code (“Code”) Section 83(b) elections. By way of background, Code Section 83(b) provides...more
Property tax is a major concern for Texas property owners, since it represents one of the most substantial expenses they face. In 2023, local taxing entities’ property tax collections totaled $82.1 billion, matching the total...more
There is a little-known asset – personal goodwill – that is present in certain types of businesses and can potentially provide a significant tax benefit when identified as part of a transaction. This article will clarify what...more
A number of Connecticut municipalities listed below are scheduled to conduct real property revaluations effective October 1, 2024. ...more
Keeping it in the family just got more complicated. Our Tax Group studies a Supreme Court decision that left a family with an unexpected estate tax liability related to a share redemption agreement....more
The Pennsylvania deadlines for appealing 2025 real estate taxes are fast approaching. There are several factors to consider in determining whether to appeal....more
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
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
Proposed federal legislation would move the time of taxation for rewards received from staking cryptocurrency and other digital assets to the time of sale. IRS guidance currently provides that staking rewards are taxed at the...more
Cryptocurrency has revolutionized the financial markets but also created tax traps for the unwary investor. Building on proposed regulations issued last year, the IRS recently increased its oversight of cryptocurrency...more
The Connecticut General Assembly's Planning and Development Committee will be holding a public hearing on March 13 at 10:00 a.m. on the following bills of interest to commercial property owners and taxpayers...more
Two recent tax court cases paint an ominous picture for professionals and investors who participated in listed syndicated conservation easement transactions. Coming on the heels of the Fisher conviction and his lengthy...more
How many times have you wished that you could undo something from your past, perhaps a string of incoherent statements made at a client dinner while slightly under the influence, or an expletive-filled email composed and sent...more
As readers of this blog probably know, a property tax appeal is initiated by filing a petition with a municipality’s Board of Assessment Appeals. Typically, the appeal must be filed with the Board no later than February 20. ...more
January 1 is the date when most third quarter tax bills are mailed in Massachusetts; therefore, under M.G.L. Chapter 59, the majority of abatement applications must be filed with local assessors’ offices on or before...more
Cheshire, Darien, New Canaan and Norwalk are among 44 Connecticut municipalities, listed in our November alert, conducting a general revaluation according to the October 1, 2023 Grand List. Depending upon the...more
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
In our continuing series on Section 704(c) of the Internal Revenue Code (the Code) we discuss the application of the remedial method to correct for distortions caused by the ceiling rule. As previously discussed, when the tax...more
Continuing with our series on the implications of the application of Section 704(c), the below discussion addresses the use of the traditional method with curative allocations. In Part 1 [insert link] we gave a broad overview...more