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Federal Taxation

  • Business-Held Real Property Drop-and-Swaps and Other 1031 Exchange Matters

    By:
    Raymond L. Liebman, Esq., CPA
    |
    Feb 1, 2026

    Section 1031 of the Internal Revenue Code of 1986 generally provides that no gain or loss is recognized when property held for productive use in trade or business or for investment is exchanged solely for like-kind property to be held for the same purpose. Over the years, litigation has focused on whether a taxpayer held the relinquished property and intended to hold the replacement property for productive use in a trade or business or investment.

  • R&D Credits After OBBBA: How CPA Firms Should Handle Prior-Year Filings and Current-Year Claims

    By:
    Alexander Lee, CPA
    |
    Feb 1, 2026

    With the One Big Beautiful Bill Act (OBBBA) came IRC section 174A, restoring current deductibility for domestic research and experimental (R&E) expenditures for tax years beginning after Dec. 31, 2024. This change reversed the mandatory capitalization and amortization regime that applied to domestic R&E beginning in 2022 under IRC section 174.

  • Lifetime Gifts and Testamentary Transfers by US Grantors to Non-Citizens

    By:
    Gary Forster, JD, LLM
    |
    Dec 1, 2025
    The US estate and gift tax is imposed on lifetime gifts and the “gross estate” of US citizens and domiciliaries (residents who intend to stay in the US indefinitely). The gross estate of a US person includes “the value at the time of death of all property, real or personal, tangible or intangible, wherever situated.” The estate and gift taxes attach to all assets regardless of the location of the US citizen or resident (or his property) at the time of gift or death.

  • Qualified Small Business Stock (QSBS): A Powerful Tax Break

    By:
    Andrew S. Katzenberg, JD, LLM, and Miguelina Mercedes, JD
    |
    Nov 1, 2025
    Few provisions of the Internal Revenue Code (the "Code") are as generous as the rules under section 1202 governing "qualified small business stock," most commonly known as QSBS. Designed to encourage investment in start-ups, section 1202 permits capital gain exclusion on all or a portion of the sale proceeds of QSBS in C corporations.

  • IRS Form 990: What Executives And the Board Should Evaluate

    By:
    By Zachary Segal, MST and Lori Rothe Yokobosky, MST
    |
    Nov 1, 2025
    While the IRS Form 990, “Return of Organization Exempt from Income Tax,” is often viewed as a routine compliance requirement, its impact and audience reach far beyond tax reporting and the IRS. For nonprofit organizations, this form can serve as a powerful public-facing tool that shapes perceptions of governance, transparency, and financial stewardship. 

  • Navigating the 2024 Form 6765 Overhaul: Key Insights for R&D Credit Practitioners

    By:
    Akshay Shrimanker, CPA, and Jay Persaud, CPA
    |
    Oct 1, 2025
    On Jun. 12, 2025, the NYCPA C-Corporation Tax Committee hosted a one-hour CPE to unpack the IRS’s comprehensive redesign of Form 6765, Credit for Increasing Research Activities, better known as the R&D Tax Credit form.

  • QOZ Planning Under the OBBBA

    By:
    Kevin Matz, CPA, JD, LLM
    |
    Sep 4, 2025
    On Jul. 4, 2025, President Trump signed into law the One Big Beautiful Bill Act,  formally known as H.R.1 – An Act to provide for reconciliation pursuant to title II of H. Con. Res. 14 (the OBBBA). The OBBBA includes provisions that establish a “second tranche” for the Qualified Opportunity Zone (QOZ) and qualified opportunity fund (QOF) program that is generally effective beginning Jan. 1, 2027.
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