Once Removed Episode 12: SLATs and the Case of McKim vs. McKim
Adult-Use Marijuana Legalization in NYS – What You Need to Know
HIPPER THAN HIP
WHERE EAGLES DARE-INTRODUCING MALTA SPLIT DOLLAR
SO VERY HARD TO GO (NOT)! In Pursuit of Puerto Rican Tax Incentives
IT NEVER RAINS IN SOUTHERN CALIFORNIA - INTRODUCING THE MALTA FREEZE
THE ACCIDENTAL ENTREPRENEUR PART V video
THE ACCIDENTAL ENTREPRENEUR PART V Podcast
Qualified Opportunity Zone Fund Investments
Impact of Tax Reform on Charitable Giving
Podcast - Chamber of Commerce v. Internal Revenue Service
On July 4, President Donald Trump signed a budget reconciliation bill entitled the “One Big, Beautiful Bill Act” (the Act). The Act extends the tax cuts that were enacted as part of the Tax Cuts and Jobs Act of 2017, adds a...more
In this fifth installment of my multi-part series on the One Big Beautiful Bill Act, Steve Nofziger and I discuss a provision of the Act that impacts certain business owners who are contemplating a sale of their shares, Code...more
The One Big Beautiful Bill Act expands the qualified small business stock benefits available to founders and investors....more
Section 1202 provides an exclusion from capital gains when a stockholder sells qualified small business stock (QSBS), assuming all eligibility requirements are satisfied. Section 1045 provides for the tax-free rollover of...more
The tax benefits conveyed by Section 1202 of the Internal Revenue Code to owners of qualified small business stock (QSBS) have been available to small business owners in some form since Section 1202 was first enacted in 1993....more
This presentation will cover essential aspects of QSBS eligibility, the tax benefits available under Section 1202, and practical approaches for maximizing exclusions on capital gains. This session will include recent updates,...more
Typically, a parent wishes to treat their children equally in their estate plan and presumes they will achieve this goal by dividing all their assets into equal shares upon their death. Accordingly, they will designate their...more
On September 16, the Internal Revenue Service issued a Notice of proposed rulemaking and notice of public hearing regarding potential amendments to policies that govern which benefits provided by Indian Tribal government...more
The IRS has issued new guidance to prevent related parties from using partnerships to achieve tax benefits through basis-shifting among assets. The IRS recently released a guidance package aimed at preventing...more
On June 17, 2024, the IRS announced the formation of a dedicated group in the Office of Chief Counsel specifically focused on developing guidance on partnerships, which is expected to work with a new “passthrough working...more
The Internal Revenue Service (IRS) is increasing audits on corporate aircraft use for high-net-worth individuals, large corporations and complex partnerships as part of its new initiative using Inflation Reduction Act funding...more
Limited liability companies (LLCs) offer significant tax flexibility – for one thing they can elect to be treated as disregarded entities, partnerships, C corporations, or S corporations, and can even shift between those tax...more
It appears that many of the country’s colleges and universities believe they have not already contributed enough to the decline of American education and to the erosion of our society, generally. These institutions of...more
Recent Government actions suggest that third-party promoters and potentially hundreds of taxpayers may be entering into abusive trust arrangements aimed at unlawfully eliminating or deferring federal income taxes....more
For some time, promoters have shopped around an arrangement known as a “section 643(b) trust,” known alternatively as a “non-grantor, irrevocable, complex, discretionary, spendthrift trust.” On August 9, 2023, IRS Chief...more
We have heard from several clients asking about ways to help their employees that suffered tremendously from the wrath of Hurricane Ian. While there are a variety of Federal, State and private relief efforts underway,...more
On August 5, 2022, the US Court of Appeals for the District of Columbia Circuit upheld the US Tax Court’s bench opinion in favor of partners and investors in a refined coal business. The Internal Revenue Service (IRS) has...more
Since coming into effect in January 2018, Subchapter Z of the US Tax Code—also known as the opportunity zone provisions—has enabled investors to pour billions of dollars into a broad array of businesses, from real estate...more
In a previous post, we discussed the tax implications for U.S. beneficiaries who receive a distribution from a foreign trust. That discussion assumed that the trust in question was, in fact, a foreign trust for U.S. federal...more
On April 17, 2019, Treasury issued its second installment of proposed regulations relating to Qualified Opportunity Zones (“QOZs”). The regulations are 169 pages in length, and (as suspected) are fairly complex. Nevertheless,...more
On March 27, 2019, the Senate Finance Committee launched an investigation into the abuse of syndicated conservation easement transactions. The transactions being investigated involve promoters selling interests in tracts of...more
There has been a lot of “buzz” in the media about Qualified Opportunity Zones (“QOZs”). Some of the media accounts have been accurate and helpful to taxpayers. Other accounts, however, have been less than fully accurate, and...more
• With Democrats taking control of the U.S. House of Representatives, tax provisions affecting tribal governments and their members are once again on the table for discussion. • This notice provides an overview of seven...more
• Proposed regulations issued on October 19 provide welcome guidance to asset managers regarding the formation of qualified opportunity funds (QOFs) that may provide investors with the following three tax benefits: (1)...more
On October 19, 2018, the U.S. Treasury Department and Internal Revenue Service (“IRS”) issued long-awaited and much anticipated proposed regulations (the “Proposed Regulations”) relating to the Opportunity Zone Fund (“OZ...more