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Federal Taxation

  • When Does 180 Equal Zero?

    By:
    Michael J. Burwick, Esq., JD, LLM and Kyle T. Kadish
    |
    Dec 1, 2022
    The tax timelines for 1031 exchanges and Qualified Opportunity Zones (QOZ) require investments to be made within 180 days of realizing a gain. The rules are clear regarding what needs to happen within each strategy that a taxpayer is pursuing, but there is little guidance on whether both timelines run concurrently or consecutively. 
  • An Insider’s Guide to IRS Examination of Financial Products and Transactions

    By:
    Michael Kramarz, JD, LLM
    |
    Nov 1, 2022

    In my prior role, I was involved in numerous examinations of financial products and transactions as a Large Business and International (LB&I) special trial attorney for the IRS. if you’re not on the inside at the IRS or have never had a client selected for an examination, you may not know its structure or procedures. But you should.

  • IRS Gets a Boost–With Possible Conditions

    By:
    Alicea Castellanos, CPA
    |
    Nov 1, 2022

    A better, stronger, faster Internal Revenue Service may soon be tracking down more wealthy tax cheats, thanks to the Inflation Reduction Act (IRA).

  • The IRS Extends the Transition Period for Enhanced R&D Tax Credit Reporting Requirements

    By:
    Peter J. Scalise
    |
    Nov 1, 2022
    On Friday, September 30, the Internal Revenue Service (the “Service”) set forth administrative guidance indicating that it is extending the transition period during which taxpayers are required to adhere to the much more arduous and onerous R&D Tax Credit reporting requirements in connection to amending tax returns within open statute years for R&D Tax Credit claims for refund.
  • How You Can Lose a Passport Due to Tax Debt

    By:
    Alicea Castellanos, CPA
    |
    Oct 1, 2022

    If you owe enough in delinquent American federal taxes, the U.S. government can take your passport. The IRS certifies “seriously delinquent” tax debt to the U.S. State Department. This is an individual's unpaid, legally enforceable federal tax debt, including interest and penalties, that totals more than $55,000. (That amount is adjusted yearly for inflation.)

  • IRS Issues Proposed Regulations on Estate Administration Expenses and Claims

    By:
    Kevin Matz, Esq. CPA, LLM
    |
    Sep 1, 2022
    Proposed Changes to IRC Section 2053 Would Introduce Present Value Concepts for Estate Tax Deductions, Limit “Graegin Loans,” Complicate Deductions where Illiquidity Results from Estate Planning, and Limit the Deductibility of Guarantee Obligations in the Absence of Entity Control.
  • Coming to America? Plan before you Plane: “Tried & True” Tax Tips to Consider Before the Move

    By:
    Timothy R. Larson, CPA
    |
    Jul 1, 2022
    It may be no surprise that the United States has more immigrants than any other country in the world. Just prior to the COVID-19 pandemic, there were an estimated 45 million immigrants living in the United States, comprising approximately 13.7% of the total U.S. population (“Frequently Requested Statistics on Immigrants and Immigration in the United States,” Migration Information Source [2021].
 

 
Views expressed in articles published in Tax Stringer are the authors' only and are not to be attributed to the publication, its editors, the NYSSCPA or FAE, or their directors, officers, or employees, unless expressly so stated. Articles contain information believed by the authors to be accurate, but the publisher, editors and authors are not engaged in redering legal, accounting or other professional services. If specific professional advice or assistance is required, the services of a competent professional should be sought.