Louis Vlahos on Tax Increases

Tax Authorities of the World Unite? Not Quite, But the IRS Joins the Movement to Tax the Rich

Earlier this year, the OECD observed there has been a significant increase in global wealth inequality over the last two decades. It also acknowledged that “taxation is a key instrument . . . that governments have at their...more

5/16/2024 / Audits , Capital Gains , Federal Budget , Foreign Governments , Inflation Reduction Act (IRA) , IRS , Net Investment Income , OECD , Presidential Elections , Surtax , Tax Authority , Tax Avoidance , Tax Increases , Tax Liability , United Nations , Wealth Tax , Whistleblowers

Estate, Gift, GST & Related Income Tax Proposals – What is the White House Doing?

Earlier this week the White House released its Fiscal Year 2025 Budget. Of course, the federal government has not yet adopted a budget for the Fiscal Year 2024 even as we approach that year’s halfway mark. But I digress. The...more

3/18/2024 / Capital Gains , Estate Tax , Exclusions , Fair Market Value , Federal Budget , Fiscal Year , Gift Tax , Grantor Retained Annuity Trusts (GRATs) , Grantor Trusts , Grantors , GST , IRS , Reporting Requirements , Revocable Trusts , Tax Credits , Tax Deferral , Tax Increases , Tax Revenues , Transfer Taxes , Trusts , U.S. Treasury , Valuation

The President’s 2024 Federal Budget: “Reforming” the Taxation of High-Income Taxpayers

The Budget and Accounting Act of 1921 established the requirement that the President submit a budget to Congress for the upcoming fiscal year. Among other things, the proposed federal budget affords the President an...more

3/13/2023 / C-Corporation , Capital Gains , Estate Tax , Federal Budget , Gift Tax , Grantor Retained Annuity Trusts (GRATs) , Grantor Trusts , IRS , Joe Biden , NIIT , S-Corporation , Tax Deferral , Tax Increases , Tax Rates

The Closely Held Business and The Tax Gap

Have you ever wondered whether you were barking up the wrong tree? That the solution to a problem may be found, not in the approach to which you were already committed and invested, but in an altogether different direction?...more

3/9/2023 / Adjusted Gross Income , Business Expenses , Closely Held Businesses , Foreign Corporations , Income Taxes , IRS , Joe Biden , Partnerships , S-Corporation , Self Employed , Tax Court , Tax Evasion , Tax Increases , Wealth Tax , Wire Transfers

Will New York Increase Taxes On Investment Income?

Last Thursday, New York State Senator Gustavo Rivera, who represents the 33rd District (basically, the northwestern quadrant of The Bronx), proposed legislation that seeks to collect more taxes from the State’s high-income...more

1/26/2023 / Capital Gains , Estate Tax , High Net-Worth , Income Taxes , Net Investment Income , New York , Selling a Business , State Taxes , Tax Increases , Tax Rates , Taxable Income , Trusts , Wealth Tax

The Schumer-Manchin Proposal To “Eliminate” the Profits Interest

Summer Break? After the last couple of weeks, I’m looking forward to Congress’s summer vacation. I’m pretty sure our elected representatives feel the same way, though it is unclear at this point when they will be heading...more

8/1/2022 / Acts of Congress , Capital Gains , Carried Interest , Federal Reserve , Holding Periods , Interest Rates , Partnership Interests , Partnerships , Price Inflation , Profits , Publicly-Traded Companies , Tax Cuts and Jobs Act , Tax Increases , Tax Loopholes , U.S. Commerce Department

Leaving New York? Can You Prove It?

“Summertime and the Living” Isn’t Easy- Summer in the New York Metro Area can be challenging. Some would say it sucks. It gets really hot. When it rains, it pours – no spritz here. The humidity is oppressive. Ironically, a...more

Revised Nonresident Audit Guidelines For New York Statutory Residence

Last Week- What a week it was. It began relatively well, with the Cowboys losing the NFC wild card game, albeit to a California team. It ended disturbingly, with the Arizona Democratic Party censuring Senator Sinema...more

1/24/2022 / Audits , Domicile , Holding Periods , Joe Biden , Jurisdiction , Lawful Permanent Residents , Non-Residents , Out-of-State Employees , Property Owners , State Taxes , Sustainability , Tax Increases , Taxable Income

Leaving New York – But What About One’s New York Business?

Goodbye New York- Late last year, the U.S. Census Bureau released data showing population shifts across the country during 2021. According to this information, New York lost 1.8 percent of its population... ...more

1/18/2022 / Apportionment , C-Corporation , Census Bureau , Closely Held Businesses , Corporate Taxes , Domicile , Exit Tax , Income Taxes , Middle Market , New York , Pass-Through Entities , Residence Status , Small Business , State of the State , Tax Advice , Tax Increases , Tax Relief , Taxable Income

Gifting Business Interests Before Selling the Business? Think Valuation

Counting the Days?- We are 302 days away from the national mid-term elections, to be held November 8, 2022, yet the first full week of the new year has already highlighted some of the economic issues with which the...more

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

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

1/4/2022 / Business Assets , Closely Held Businesses , IRS , Limited Liability Company (LLC) , New York , Partnerships , Pass-Through Entities , Private Equity , QSub , Reorganizations , Revenue Procedures , S-Corporation , SALT , Shareholders , Tax Increases , Tax Liability , Transfer Taxes

The Tax-Deferred Rollover – Some Considerations

“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

Selling Your S Corporation’s Business? What If It’s Not an S Corporation?

Haste Makes Waste? How many of you are suffering from Build Back Better Fatigue? Seriously, it’s a thing. Sure, the House passed its version of the President’s tax and spending bill on November 19, and the Senate...more

12/9/2021 / Beneficiaries , Business Ownership , C-Corporation , Capital Gains Tax , Closely Held Businesses , Good Faith , IRS , Reorganizations , Restructuring , S-Corporation , Sale of Assets , Shareholders , Target Company , Tax Increases , Trustees , Trusts , Ways and Means Committee

Not Selling Despite Tax Increases? Review the Buy-Sell Agreement Among Owners

Not Selling Your Business This Year? Beginning shortly before the House Ways and Means Committee released its version of the President’s Build Back Better plan, several posts on this blog have explored the uptick in M&A...more

11/29/2021 / Arms Length Transactions , Business Ownership , Buy-Sell Agreements , Corporate Taxes , Equity , Estate Tax , Fair Market Value , Family Businesses , Income Taxes , IRS , Life Insurance , Liquidity , Mergers , Partnerships , Shareholders , Stock Purchase Agreement , Tax Increases , Transfer of Assets , Ways and Means Committee

The 2022 Federal Budget, Including Tax Changes – Are We There Yet?

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

Maybe Tax the Rich, but Not The Conversion of S corps into Partnerships – What Gives?

Tax the Rich? A few days ago, an opinion piece that appeared in the Wall Street Journal began as follows: “President Biden’s effort to pass the largest tax increase in U.S. history is based on the verifiably false...more

10/18/2021 / Built-In Gains , C-Corporation , Congressional Budget Office , Corporate Taxes , Fair Market Value , Joe Biden , Limited Liability Company (LLC) , Liquidation , OECD , S-Corporation , Sale of Assets , Shareholders , Tax Increases , Taxable Income , Ways and Means Committee , Wealth Tax

Gifts, Sales and Effective Dates: The Race Against the Clock the Taxpayer Cannot See

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

Tax Hikes, Senator Manchin, and Effective Dates – OH MY!

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

Disposing Of Assets Under The Ways and Means Committee’s Proposals

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

Tax Hikes, Effective Dates, And Selling a Business

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

Tax Increases Are In Sight

Summertime in Washington- On August 11, the Senate passed the $3.5 trillion budget resolution for the 2021-2022 fiscal year – S. Con. Res. 14, as amended – by a vote of 50 to 49, strictly along party lines, including...more

9/7/2021 / Budget Reconciliation , Closely Held Businesses , Congressional Budget Resolution , Earn-Outs , Escrow Accounts , Estate Tax , General-Business , Gift Tax , Legislative Agendas , Popular , SALT , Selling a Business , Tax Increases , Tax Rates , Transfer of Assets

Tax Distributions As Fraudulent Conveyances?

The Calm Before? I’m confused. For better or worse, I’m pretty sure that I am not alone. Last week, in a letter addressed to the American people, forty-six of the fifty Republicans in the U.S. Senate indicated they...more

8/16/2021 / Bankruptcy Code , Biden Administration , Budget Reconciliation , C-Corporation , Chapter 11 , Commercial Bankruptcy , Debtors , Infrastructure , Limited Liability Company (LLC) , Liquidation , Pass-Through Entities , Private Equity Funds , Tax Increases , Taxable Distributions , Trustees

Louis Vlahos

Rivkin Radler LLP

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