Latest Articles

  • The Current State of Leveraged Partnership Structures and Liability Allocations

    By:
    Jorge Otoya, CPA and Jim Dubeck
    |
    Nov 1, 2017
    One of the many benefits of using partnerships to conduct business is that a partner can include its allocable share of partnership liabilities in the tax basis of its partnership interest (“outside basis”). 
  • Tax Court Declines to Follow Revenue Ruling 91-32 in Grecian Magnesite Mining Case

    By:
    Ari Berk, Jim Calzaretta, Paul Epstein, JD, LLM (taxation) and Christine Piar, JD
    |
    Nov 1, 2017
    After a three-year period following the trial and briefs from the taxpayer and the IRS, during which the Obama administration each year sought legislation ratifying the IRS’s position in Revenue Ruling 91-32, the Tax Court has finally issued its opinion declining to follow the ruling.
  • Avoiding the Exit Tax

    By:
    Philip D. W. Hodgen
    |
    Nov 1, 2017

    Every year, more and more U.S. citizens renounce their citizenship, and green card holders give up their visa status. These actions trigger a tax problem: the exit tax.

  • Social Security Benefits for Non-Working Spouses

    By:
    Daniel Mazzola, CPA, CFA
    |
    Nov 1, 2017
    In 1945, Michigan’s legislators passed a law requiring all bartenders to be licensed but prohibiting women to secure such licenses unless they were the wives or daughters of male bar owners. 
  • Tools and Techniques to Shield and Defer Taxes On Unrealized Stock Gains

    By:
    Thomas Boczar, ESQ., LLM, CPWA, CFA, and Elizabeth Ostrander, CFA
    |
    Oct 1, 2017
    What strategies might investors consider to strategically manage their single-stock risk over a longer-term period? Exchange funds, stock protection funds, and completeness portfolios are the primary tools investors can use to manage their stock concentration risk over a long-term period.
  • Long-Term Care Premiums Paid by New York Resident Taxpayers: A Potential Double Benefit

    By:
    David M. Barral, CPA/PFS, CFP
    |
    Oct 1, 2017

    For those who are proactive in planning for their end-of-life care, purchasing long-term care (LTC) insurance is a great idea. There are also tax benefits available for the premiums paid. Most CPAs are familiar with considering these premiums as an itemized deduction at the federal level under IRC section 213(d)(1)(D), but these premiums are not 100% deductible—it is adjusted annually and limited by the age of the taxpayer.

  • Key Tax Issues in Negotiating M&A Deals for Small Businesses

    By:
    Jordan L. Fieldstein, JD, LLM (taxation) and Michael P. Spiro, JD, LLM (taxation)
    |
    Oct 1, 2017
    Negotiating the sale of a small business begins with striking the commercial bargain between the parties. The alternative tax structures available to effect a single transaction, however, can have a significant impact on the parties’ economic bargain. 
  • Information Exchange With the United Kingdom Leads to Adjustment in Foreign Tax Credit Claimed

    By:
    Charles Ladas, CPA, and Joseph Neri, CPA
    |
    Oct 1, 2017
    As the global economy becomes more aligned, it is common for businesses and individuals today to have income and tax compliance issues in more than one country. With the complexity of varying tax regimes and the difficulty in monitoring offshore tax compliance, governments and taxing authorities around the world are looking for ways to collaborate and ensure taxpayers are paying their fair share, wherever they may be. 
  • To Grant(or) Not? Choosing the Right Structure for Your Special Needs Trust

    By:
    Ashley Velategui, CFA
    |
    Sep 1, 2017
    Raising a special needs child can be one of life’s greatest joys, but their parents face unique challenges—not the least of which is figuring out how to financially provide for the child after both parents have passed away. 
  • New York State Residency Audits: What Is Credible Testimony?

    By:
    Brian Gordon, CPA
    |
    Sep 1, 2017
    There are two different ways a person can be considered a resident of New York State or New York City for tax purposes. The first way is to be deemed “domiciled” in New York. Depending on the circumstances, an analysis to determine domicile can be complex—but generally, you are domiciled in New York City or New York State if it is your place of primary residence. 

Tax Quote

“Income tax has made more liars out of the American people than golf.” 


- Will Rogers

Death, taxes and childbirth! There's never any convenient time for any of them.
*Outside the Box is a new addition to the TaxStringer featuring important articles on financial and investment management topics by top authors who have expertise both inside and outside the realm of taxation.

 

 

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