Corporate Taxation

  • New Power of Attorney Law

    By:
    Pauline Yeung-Ha, Esq.
    |
    Jul 1, 2021

    For over a decade, New Yorkers have been using the New York State Statutory Short Form Power of Attorney (“2010 POA”) which also contained the Statutory Gifts Rider. The implementation and execution of the 2010 POA have been confusing and complex for most New Yorkers. 

  • Section 958(b)(4) Repeal and the Proliferation of the Constructive CFC

    By:
    Summer A. LePree, Esq., JD, LLM (taxation) and Jeffrey L. Rubinger, Esq., JD, LLM (taxation), CPA (inactive)
    |
    Jun 1, 2021
    The impact of the Tax Cuts and Jobs Act (TCJA) was particularly significant in the cross-border context, where taxpayers and practitioners saw drastic changes come into effect almost overnight. One of the most disruptive and wide-reaching changes was the repeal of Section 958(b)(4), which historically had prevented the downward attribution of stock from foreign persons to U.S. entities in the context of the U.S. controlled foreign corporation (CFC) provisions.
  • The U.S. Taxation of Foreign Pensions

    By:
    Christopher Callahan, Esq., LLM, JD
    |
    Mar 1, 2021

    This article presents a summary of the U.S. tax and reporting obligations with which a U.S. citizen must comply in connection with his or her interest in a foreign defined contribution plan that is organized by active companies with numerous employees. Any references in this article to a “foreign plan,” a “foreign pension,” or similar phrases are meant to describe such plans.

  • Non-Qualified Deferred Compensation as an Employee Retention Tool

    By:
    Joshua P. Friedlander, Matthew E. Rappaport, JD, Esq., LL.M., and Daniel P. Knudsen, Esq., LL.M.
    |
    Dec 1, 2020
    Even in a labor market and greater economy ravaged by coronavirus disease (COVID-19), good help is still hard to find.  Business owners might be focusing on how to navigate the pandemic and keep the company alive, but the threat of a competitor poaching an enterprise’s best people looms in the background.  Small businesses are particularly vulnerable to losing their best people because a larger competitor could offer a lucrative package to entice even the most loyal employee to jump ship.
  • Interest Rates and Planning: What You Need to Know

    By:
    Blanche Lark Christerson, JD, LLM (taxation)
    |
    Oct 1, 2020

    Interest rates are at historic lows. This is good news for certain planning techniques and bad news for others.   

    Specifically, low interest rates work extremely well if an estate “freeze” technique involves an annuity or a loan and work poorly if a freeze technique involves income and reversionary interests. In other words, low interest rates make this a good time for grantor retained annuity trusts (GRATs), sales to “defective” grantor trusts (Sales) and charitable lead annuity trusts (CLATs), but a bad time for qualified personal residence trusts (QPRTs) and charitable remainder annuity trusts (CRATs).
  • Tax Exemption: What Nonprofit Executives, Board Members, and Auditors Need to Know (Part 2 of 2)

    By:
    Allen L. Fetterman, CPA, MBA
    |
    May 1, 2020
    Published in the April issue of TaxStringer, part 1 of this series provided a beginning overview of the basics of tax exemption. This article will continue that discussion, focusing especially on tax exemption with respect to jeopardizing tax-exempt status, lobbying, the Form 990 series, and state laws.
  • Tax Exemption: What Nonprofit Executives, Board Members, and Auditors Need to Know (Part 1 of 2)

    By:
    Allen L. Fetterman, CPA, MBA
    |
    Apr 1, 2020

    Many nonprofit executives, board members, and their auditors are familiar with Form 990—some auditors might even prepare it. Yet many of these professionals don’t know enough about what needs to be done to obtain and maintain tax-exempt status, and they’re not aware of actions that could jeopardize that status. For that reason, this discussion provides a beginning overview of the basics of tax exemption—and will be continued in an upcoming article in next month’s TaxStringer.

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