Federal Taxation

  • The Effect of the Tax Cuts and Jobs Act of 2017 on Expatriation

    By:
    Shannon P. McNulty, Esq., LLM (Taxation), CFP
    |
    Feb 1, 2018

    Affluent U.S. citizens and long-term legal permanent residents (i.e., green card holders) looking to expatriate from the United States can face a daunting financial obstacle in the form of the exit tax regime imposed by IRC section 877A. While the recently enacted tax law leaves IRC section 877A unchanged, it effects other changes to the IRC that can make it easier for those seeking to expatriate to get out from under IRC section 877A penalties.

  • Employee Stock Ownership Plans: Exploring Opportunities for Business Owners

    By:
    Kevin Jennings, ABV, CVA and Carla Klinger
    |
    Jan 1, 2018
    An employee stock ownership plan (ESOP) is a qualified retirement plan under IRC section 401(a) that is nondiscriminatory and provides transition opportunities for a company’s owners. But an ESOP is not for everyone—the company must be robust and produce sufficient cash flow to cover the expenditures associated with an ESOP.  
  • Choice of Entity

    By:
    Dean L. Surkin, JD, LLM
    |
    Jan 1, 2018
    When entering a new business transaction (or significantly changing an existing one), clients should consider their choices of entity and business structure. They must consider the requirements of the business, the extent or liability protection, and the tax effects, and we, as their principal tax advisors, should work closely with their attorneys in making informed choices.
  • Divorce and Taxes

    By:
    Stewart Berger, CPA
    |
    Dec 1, 2017

    In the United States, there is a divorce every 36 seconds—or about 876,000 per year. The average marriage lasts approximately eight years before a couple gets divorced. Most people who get divorced, however, do not know the tax consequences or ramifications.

  • 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.

  • France Delays Implementation of New Tax Withholding System for One Year

    By:
    Michael Jaffe, Christophe Flaicher, PhD, and Bertrand Hermant, PhD, LLM
    |
    Sep 1, 2017
    In our May 2017 article, we mentioned that the implementation of a current year “pay-as-you-earn” (PAYE) withholding tax fell during an election year—and that the new president could get cold feet when confronted with this major change to the tax collection process.
  • 'Placed in Service' Does Not Mean 'Open for Business'

    By:
    Dennis Zinkevich, CPA
    |
    Jul 1, 2017
    On Apr. 13, 2017, the IRS issued an official Action on Decision (“AoD”) regarding its defeat in Stine, LLC v. United States. Stine addressed whether a building can be considered to be “placed in service”—meaning it is substantially complete and in a state of readiness and availability to carry out its specified function—before it is “open for business” for purposes of depreciation and the special Gulf Opportunity Zone (“Go Zone”) bonus depreciation. 
 

 
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