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Federal Taxation

  • The YA Global Tax Court Decision: Private Fund Activities Drag Non-U.S. Fund Investors Into the U.S. Tax Net

    By:
    Mark Leeds
    |
    Jun 3, 2024
    For U.S. history aficionados, November 15 is an auspicious day: It was on this day in 1777 that the Continental Congress approved the Articles of Confederation. These articles framed the basic form of government for what was to become the United States. Well, tax folks working with private funds are likely to remember November 15 for another reason as well. 

  • Nothing to Fear but Fear Itself: Planning in the Current Environment

    By:
    Carl Fiore, JD, LLM
    |
    May 1, 2024
    As the calendar turns to 2024, taxpayers and their advisors face an uncertain future.  Given a divided government for at least the next two years, it is not the usual suspect of potential legislation and sweeping tax changes that fuels this uncertainty. Instead, a declining market, the potential for recession looming, and increasing interest rates has left many taxpayers in a general malaise heading into the new year. However, while this overall economic downturn presents at least short-term challenges, it also creates certain wealth planning opportunities.

  • A Practical Discussion with Respect to Internal Revenue Code Section 1031—The "Like Kind" Tax-deferred Exchange, Part 3

    By:
    Raymond L. Liebman, Esq., CPA
    |
    Apr 1, 2024

    This is the final part of a three-part series explaining the basics of the tax-deferred 1031 exchange, the different types available, the mechanics of how they work, and the benefits to be reaped by a client who decides to partake in such an exchange. To view Part 1, please click here. To view Part 2, please click here.

  • Getting Back to Basics: Securities Analysis and Section 475 Elections

    By:
    Brandon Blitzer, CPA and Edward Weissman, CPA
    |
    Apr 1, 2024
    In the dynamic world of financial markets, investors and traders employ various strategies to maximize returns and manage risks. However, these strategies often come with complex (at times, costly) tax implications that can significantly affect the taxable income reported. Understanding the common tax adjustments that arise from trading in the financial markets (e.g., wash sales, straddle adjustments, constructive sales) and the methods to remedy or control the amount of the adjustments are key to a tax-efficient trading strategy.

  • A Practical Discussion with Respect to Internal Revenue Code Section 1031—The "Like Kind" Tax-deferred Exchange, Part 2

    By:
    Raymond L. Liebman, Esq., CPA
    |
    Mar 1, 2024

    This is the second part of a three-part series explaining the basics of the tax-deferred 1031 exchange, the different types available, the mechanics of how they work, and the benefits to be reaped by a client who decides to partake in such an exchange. To view Part 1, please click here.

  • Considerations of S-Corp Acquisitions

    By:
    Thomas Mitchell, Esq., and Brian Krastev, Esq.
    |
    Jan 3, 2024
    When buying or selling a business, the existence of a target company that is taxed as a subchapter S corporation (an “S Corporation”) can be advantageous for all parties to a transaction. The acquisition of an S Corporation, however, presents unique tax considerations that are vital for both buyers and sellers to understand.

  • Proposed Bipartisan Legislation on Opportunity Zones and Qualified Opportunity Funds Would Extend the Investment and Gain Deferral Period By Two Years and Permit Investment in a Fund of Funds

    By:
    Kevin Matz, Esq., CPA, LLM
    |
    Dec 1, 2023

    On September 27, 2023, H.R. 5761, the “Opportunity Zones Transparency, Extension and Improvement Act,” was introduced as bipartisan legislation in the House of Representatives (the “proposed legislation”).[1]  Among other things, the proposed legislation, if enacted into law, would extend the investment and tax deferral period for capital gains that are invested in qualified opportunity funds (QOFs) by two years (from December 31, 2026 to December 31, 2028) and permit QOFs to be structured as a fund of funds.
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