“Déjà vu All Over Again”-
The White House last week released the President’s Budget for the Fiscal Year 2023. The Budget is ambitious, but its “investments,” we are told, “are more than paid for with tax reforms focused on...more
4/8/2022
/ Capital Gains ,
Capital Gains Tax ,
Estate Tax ,
Fair Market Value ,
Family Businesses ,
Federal Budget ,
Gift Tax ,
Grantor Retained Annuity Trusts (GRATs) ,
Grantor Trusts ,
Income Taxes ,
Joe Biden ,
Rule Against Perpetuities ,
Taxable Income ,
Transfer Taxes ,
Trusts ,
Wealth Tax
“I have wondered at times what the Ten Commandments would have looked like if Moses had run them through the U.S. Congress.” – Pres. Ronald Regan-
That line probably describes the exasperation with which many Americans...more
12/14/2021
/ Acquisitions ,
Business Ownership ,
Capital Gains ,
Closely Held Businesses ,
Fair Market Value ,
Federal Budget ,
Income Taxes ,
Partnerships ,
Private Equity ,
Stocks ,
Target Company ,
Tax Code ,
Tax Deferral ,
Tax Increases ,
Tax-Free Exchanges
Tax the Rich?
The President’s plan for a tax regime that would ensure the rich pay their “fair share” of the cost of implementing his programs has come one step closer to being realized . . . maybe . . . well, sort of ....more
11/23/2021
/ Adjusted Gross Income ,
C-Corporation ,
Capital Gains ,
Capital Gains Tax ,
Corporate Taxes ,
Estate Tax ,
Gift Tax ,
Grantor Retained Annuity Trusts (GRATs) ,
Income Taxes ,
Infrastructure ,
Inter Vivos Gifts ,
IRS ,
Mark-To-Market ,
Net Investment Income ,
Social Security Taxes ,
Tax Code ,
Tax Court ,
Tax Liability ,
Tax Returns ,
Transfer Taxes ,
Valuation ,
Wealth Tax
Having Fun?
Hope you had a decent weekend. Perhaps you did something interesting, maybe even fun, like some end-of-season apple picking? Or maybe you had a cider donut with some hot coffee at a farm stand you stumbled upon...more
11/10/2021
/ Acquisitions ,
Adjusted Gross Income ,
Capital Gains ,
Fair Market Value ,
IRS ,
Limited Liability Company (LLC) ,
Long-Term Investment Funds ,
Mergers ,
Net Investment Income ,
Partnerships ,
Popular ,
Private Equity ,
Reorganizations ,
Rollover Equity ,
S-Corporation ,
Sale of Assets ,
Surcharges ,
Surtax ,
Tax Deductions
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
11/1/2021
/ Budget Reconciliation ,
Capital Gains ,
Corporate Taxes ,
Federal Budget ,
Grantor Trusts ,
Green Book ,
Income Taxes ,
IRS ,
Like Kind Exchanges ,
Popular ,
SALT ,
Tax Increases ,
Ways and Means Committee ,
Wealth Tax
It was quite a week, wasn’t it?-
Manchin-
Senator Manchin continued to attract a lot of attention.
To the dismay of his fellow Democrats, the West Virginian – who also chairs the Senate Energy and Natural Resources...more
10/13/2021
/ Business Ownership ,
Business Taxes ,
Capital Gains ,
Carbon Taxes ,
Clean Energy ,
Closely Held Businesses ,
Debt Ceiling ,
Estate Tax ,
Estate-Tax Exemption ,
Gift Tax ,
Gift-Tax Exemption ,
Grantor Retained Annuity Trusts (GRATs) ,
Grantor Trusts ,
Irrevocable Trusts ,
IRS ,
Joe Biden ,
OECD ,
Pandora Papers ,
Private Equity ,
SALT ,
Tax Increases ,
Tax Rates ,
Valuation ,
Ways and Means Committee
What was your month like?
If you’re a transactional professional – a class in which I include those who advise clients on the purchase and sale of businesses and investment assets, as well as those who assist clients in...more
10/5/2021
/ Budget Reconciliation ,
Business Ownership ,
Capital Gains ,
Closely Held Businesses ,
Federal Taxes ,
Joe Biden ,
Popular ,
Tax Code ,
Tax Cuts and Jobs Act ,
Tax Increases ,
Ways and Means Committee
First Step-
Last Wednesday, the House Ways and Means Committee approved that portion of the 2022 budget legislation with which it was tasked by the Congressional Budget resolution of August 24. The text of the bill...more
9/21/2021
/ Adjusted Gross Income ,
Business Assets ,
Business Income ,
C-Corporation ,
Capital Gains ,
Corporate Taxes ,
Estate Tax ,
Gift Tax ,
Grantor Trusts ,
Investors ,
Joe Biden ,
Limited Liability Company (LLC) ,
Liquidation ,
Qualified Small Business Stock ,
S-Corporation ,
Shareholders ,
Subsidiaries ,
Surtax ,
Tax Increases ,
Taxable Income ,
Valuation ,
Wealth Tax
Living the Dream-
“How was your weekend?” Thank you for asking. Awful.
“Why?” you ask. (Humor me. Pretend you’re interested.) I’ll tell you. One word, with 535 syllables: Congress.
When the reconciliation budget...more
9/13/2021
/ Biden Administration ,
Business Ownership ,
Business Taxes ,
Capital Gains ,
Corporate Taxes ,
Green Book ,
Income Taxes ,
Partnerships ,
Popular ,
Reconciliation ,
Tax Increases ,
Tax Revenues ,
Wealth Tax
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
8/23/2021
/ Business Ownership ,
Capital Assets ,
Capital Gains ,
Corporate Taxes ,
Estate Tax ,
Income Taxes ,
Like Kind Exchanges ,
Long-Term Investment Funds ,
New York ,
S-Corporation ,
Stock Transfer ,
Tax Fraud ,
Tax Legislation ,
Tax Rates ,
Transfer on Death Deed (TOD) ,
Transfer Taxes
Compare and Contrast-
Have you spoken to anybody about the infrastructure bill on which the Senate is about to vote? I know I haven’t, except to explain that Speaker Pelosi has stated the House will not consider the bill...more
8/9/2021
/ C-Corporation ,
Capital Gains ,
Estate Planning ,
Grantor Trusts ,
Infrastructure ,
Non-Resident Aliens ,
PCBs ,
Popular ,
S-Corporation ,
Small Business ,
Tax Increases ,
Tax Rates
Head-Scratchers-
The Code is chock-full of provisions that will challenge the intellectual capacity, not to mention the patience, of most tax professionals. The complexity of these rules does not arise out of some sadistic...more
Not Good-
As Mr. Biden settled into the White House, and as the Democrats began planning how to best utilize their slim Congressional majority to enact and pay for their sweeping legislative agenda, the principal concern...more
6/29/2021
/ Budget Reconciliation ,
Capital Gains ,
Closely Held Businesses ,
Green Book ,
Joe Biden ,
Pass-Through Entities ,
Popular ,
Portfolio Companies ,
Tax Increases ,
Tax Rates ,
U.S. Treasury ,
Wealth Tax
Extra, Extra!-
Last Friday afternoon, as millions of unsuspecting Americans prepared for the long Memorial Day weekend – for many, perhaps, their first mask-less holiday celebration in almost 15 months – the Biden...more
6/2/2021
/ Adjusted Gross Income ,
Biden Administration ,
C-Corporation ,
Capital Gains ,
Closely Held Businesses ,
Corporate Taxes ,
Dynasty Trust ,
Fair Market Value ,
Family Businesses ,
Federal Budget ,
Fiscal Year ,
Gift Tax ,
Green Book ,
Interest Rates ,
Irrevocable Trusts ,
IRS ,
Like Kind Exchanges ,
Loans ,
Long-Term Investment Funds ,
Popular ,
Public Charities ,
Revocable Trusts ,
Spouses ,
Tax Cuts and Jobs Act ,
Tax Increases ,
Taxable Income ,
Transfer Taxes ,
Trust Assets ,
Trusts ,
U.S. Treasury
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
5/25/2021
/ Audits ,
Business Expenses ,
Business Losses ,
Business Taxes ,
C-Corporation ,
Capital Expenditures ,
Capital Gains ,
CCA ,
Closely Held Businesses ,
Enforcement ,
Income Taxes ,
IRS ,
Like Kind Exchanges ,
Long-Term Investment Funds ,
Net Investment Income ,
Partnerships ,
Pass-Through Entities ,
Real Estate Investments ,
S-Corporation ,
Shareholders ,
Tax Advice ,
Tax Deductions ,
Tax Increases ,
Tax Rates ,
Taxable Income ,
U.S. Treasury
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
5/17/2021
/ Biden Administration ,
Bona Fide Purchaser ,
Capital Gains ,
Cash Transactions ,
CCA ,
Closely Held Businesses ,
Estate Tax ,
Fair Market Value ,
Federal Taxes ,
Income Taxes ,
Investigations ,
IRS ,
Joe Biden ,
OCC ,
Promissory Notes ,
Tax Advice ,
Tax Deferral ,
Tax Increases ,
Tax Liability ,
Unsecured Debt
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
5/11/2021
/ Capital Gains ,
Estate Tax ,
Income Taxes ,
Installment Agreements ,
Internal Revenue Code (IRC) ,
Investment Property ,
Joe Biden ,
Like Kind Exchanges ,
Political Campaigns ,
Real Estate Investments ,
S-Corporation ,
Step-Up Basis ,
Tax Increases ,
Tax Planning
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
5/3/2021
/ Capital Assets ,
Capital Gains ,
Closely Held Businesses ,
Corporate Taxes ,
Estate Tax ,
Fair Market Value ,
Gift Tax ,
IRS ,
Joe Biden ,
Liquidity ,
Qualified Small Business Stock ,
Tax Cuts and Jobs Act ,
Tax Fraud ,
Tax Liability ,
Taxable Income ,
Wealth Tax
In advance of the President’s address to Congress this evening, the White House this morning released a summary of Mr. Biden’s proposed changes to the Internal Revenue Code. These changes, together with his previously...more
“Yeah, I’m the Tax Man”
Last week, several media outlets reported that Mr. Biden will soon propose that Congress increase the federal income tax rate applicable to long-term capital gains recognized by individual...more
4/26/2021
/ American Taxpayer Relief Act of 2012 (ATRA) ,
Baby Boomers ,
Budget Reconciliation ,
Business Assets ,
Business Ownership ,
Business Taxes ,
Capital Gains ,
Census ,
Closely Held Businesses ,
Deferred Compensation ,
Depreciation ,
Economic Downturn ,
Income Taxes ,
IRS ,
Joe Biden ,
Loans ,
Pass-Through Entities ,
Personal Property ,
Popular ,
Retirement Funds ,
Tangible Property ,
Tax Deductions ,
Tax Increases ,
Tax Reform ,
Tax Relief Act of 2010 ,
Tax-Free Transfers ,
Taxable Income
According to Justice Learned Hand, “Any one may so arrange his affairs that his taxes shall be as low as possible; he is not bound to choose that pattern which will best pay the Treasury; there is not even a patriotic duty to...more
4/5/2021
/ Business Expenses ,
Business Taxes ,
Capital Gains ,
Enforcement ,
Estate Tax ,
False Claims Act (FCA) ,
Infrastructure ,
IRS ,
Joe Biden ,
New York ,
Qui Tam ,
Shell Corporations ,
State Attorneys General ,
State Taxes ,
Tax Audits ,
Tax Avoidance ,
Tax Increases ,
Tax Liability ,
Tax Planning ,
Wealth Tax ,
Whistleblowers ,
Withholding Tax