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
This is the third edition of the Eversheds Sutherland SALT Scoreboard for 2024. Since 2016, we have tallied the results of what we deem to be significant taxpayer wins and losses and analyzed those results. Our entire SALT...more
Over the last couple of years, several of my friends have become citizens of the country from which their parents emigrated to the U.S. Also during that period, some acquaintances took advantage of the so-called “golden...more
It is a basic principle of the income tax that the gain or loss realized by a taxpayer from the conversion of property into cash, or from the exchange of property for other property that differs materially in kind from the...more
The accounting rules for the Pennsylvania Personal Income Tax do not follow the Federal Tax Code. Instead, they follow generally accepted accounting principles....more
Allen Matkins partner Jared Kassan participated on a panel earlier this year to discuss legal issues surrounding partnerships and 1031 exchanges. The panel began by discussing the traditional “drop and swap” strategy with its...more
On March 28, 2022, the Biden Administration released its budget proposal for Fiscal Year 2023 (the Budget). We summarize below the tax aspects of the Budget of particular interests to U.S. corporate taxpayers, financial...more
It Seemed Like a Good Idea- In July of this year, one of my partners, who chairs the board of a local grantmaking public charity, asked if I would present at a CLE program to be sponsored by the charity on October 28 (last...more
This chart compares the Biden Administration’s Fiscal Year 2022 Revenue Proposals (the Greenbook), to the tax proposals in the Build Back Better Act (BBBA) approved by the House Ways and Means Committee on September 15, 2021....more
It is said that two things are certain in life: death and taxes. True, but incomplete. What is missing from this short list is a third inevitable occurrence – tax law changes. We now have a new and pressing series of proposed...more
In April 2021, President Biden announced the “American Families Plan,” which included some significant tax law changes. On May 28, 2021, the United State Department of Treasury issued a report entitled “General Explanation of...more
Welcome to the Governor’s office, Ms. Hochul. Unfortunately, congratulations are hardly in order; indeed, a wish for good luck seems much more appropriate. I suppose you realize that the last round of tax legislation,...more
In a recent Chief Council Advisory, the IRS found that certain cryptocurrencies did not qualify as like-kind exchanges under section 1031 prior to the Tax Cuts & Jobs Act of 2017. The IRS’s ruling, while limited to coin...more
President Biden has proposed major changes to the Federal tax laws, some of which are sought to be effective earlier in 2021 (i.e., we are already operating under these changes, if they later become adopted), as compared to...more
Tax Gap- In a report released last week, the U.S. Treasury Department explained that the so-called “tax gap” – i.e., the difference between the amount of federal income taxes owed by taxpayers for a taxable year and the...more
On April 28, 2021, the White House issued a fact sheet which set forth some additional details on the tax increase proposals contained in President Biden’s “American Families Plan.” ...more
On April 28, 2021, President Biden announced a plan to expand benefits for lower- and middle-income Americans under his “American Families Plan” (the “Plan”). To pay for the Plan’s benefits, President Biden has proposed...more
Go After Real Estate? During the 2020 presidential campaign, there was one segment of the “rich” for which then-candidate Biden seemed to have reserved some of his harshest criticism – wealthy real estate investors....more
The Biden-Harris administration on April 28 introduced the American Families Plan (AFP), a $1.8 trillion legislative framework including provisions to “grow the middle class, expand the benefits of economic growth to all...more
The American Families Plan is the third part of the Biden Administration's Build Back Better agenda, addressing "human infrastructure" and containing proposals on free education, direct support to children and families, and...more
This past November, we outlined selected tax law changes that President-elect Joe Biden has proposed, both in speaking engagements and on his campaign website, some or all of which could be enacted in 2021 or future years. ...more
Just days before we all sat down to eat our Thanksgiving dinners, the Treasury Department gave us something else to digest: final like-kind exchange regulations. These regulations define “real property” for purposes of Code...more
Presented below is our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of November 23, 2020 – November 27, 2020... November 23, 2020: The IRS released TD 9935, providing...more
With Biden as the projected President-Elect (subject to pending federal litigation and the Electoral College vote), tax planning for late 2020, 2021, and beyond is top of mind for many businesses and individuals....more
The Convention- The Democratic Party’s “virtual” convention last week seems to have gone pretty well. All the stars of the Party’s firmament were on hand and spoke in “virtually” one voice in their assessment of the...more