KNOCK YOURSELF OUT - RESUSCITATING TAXPAYERS WITH BUYER'S REMORSE!
In this Part XV of my multi-part series on some of the not-so-obvious aspects of Subchapter S, I explore a potential advantage that the S corporation has over the C corporation. The Patient Protection and Affordable Care...more
Is a new wave of U.S. expatriate income tax refund applications on the table? The answer to this question hangs in the balance as we await an appeal on the question of whether or not specific Foreign Tax Credits can be...more
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
Many of you, perhaps most, may have read about a case that will be heard by the U.S. Supreme Court during its current term. The case, Moore v. United States, comes out of the Ninth Circuit Court of Appeals. The Supreme Court...more
Today, maximizing the use of your limited capital is especially important because: margins continue to be squeezed, access to capital has become more difficult, the cost of capital continues to rise, the cost of...more
The Washington Court of Appeals has held that investment funds are subject to Washington state business and occupation (B&O) tax on their investment income. Although Washington law allows taxpayers to deduct “amounts derived...more
Like Peas in a Pod? What do private, not-for-profit colleges and hospitals have in common? There are quite a few items that come immediately to mind: •They may qualify for exemption from federal income tax. •Tax-exempt...more
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
2022 has been a busy year for most people. As this year is rushing toward the end, it is important ensure that you have taken advantage of the planning options available to you. Income Tax Planning Opportunities- The first...more
Presented below is our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of September 12, 2022 – September 16, 2022...more
The Department of Finance recently released a package of materials containing potential changes to the Canadian tax system (Tax Proposals). The materials, released on August 9, 2022, include draft amendments to the Income Tax...more
Cryptocurrencies might, simplistically, be defined as virtual currencies that use cryptography to secure transactions which are digitally recorded on a widely distributed ledger. The ledger technology uses independent...more
Review of U.S. Tax Developments in 2021- Last year, we predicted that the biggest U.S. tax news in 2021 would be revenue-raising legislation that the Democrats would put forward after the election of Joe Biden as the 46th...more
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
In general, tax experts were pleased that the Build Back Better Act, passed recently by the U.S. House of Representatives, did not include many of the tax increases previously proposed by the Biden Administration. ...more
Overview - Over the past year, several tax law changes have been proposed by the Biden administration and, in September 2021, draft legislative language was circulated, which set forth proposed changes to the Internal...more
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
Here's a summary of the tax provisions in the Build Back Better Act, as passed by the House. I. Introduction - On November 19, 2021, the House of Representatives passed the Build Back Better Act (the BBBA)....more
Same old in D.C.- On Monday, November 15, the President will sign into law the approximately $1 trillion Infrastructure Investment and Jobs Act that was finally passed by Congress when the House approved the Senate’s...more
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
...The federal tax laws are certainly about to change. With the need to raise revenue as a top priority for the Biden Administration, everyone is expecting dramatic changes to the Internal Revenue Code. Tax legislation is...more
The House Ways and Means Committee advanced key tax reform proposals on September 15 that would increase taxes for corporations and high-income individuals. Several tax reform proposals are under consideration as part of...more
Congress has other plans for tax practitioners this fall, starting with the House Ways and Means Committee’s initial draft of major tax legislation. The draft legislation proposes far-reaching changes to existing tax laws,...more
Freeman Law’s “The Tax Court in Brief” covers every substantive Tax Court opinion, providing a weekly brief of its decisions in clear, concise prose. The Week of August 16 – August 20, 2021 - Catlett v. Comm’r, No....more
Report Card- A couple of weeks ago, the Treasury Inspector General for Tax Administration (“TIGTA”) released a report that presented the results of its review to determine whether the IRS’s “policies, procedures and,...more