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Federal Taxation

  • A Tale of Two Citizenships: Taxation of American Citizens with Dual Citizenship Living Abroad

    By:
    Alicea Castellanos, CPA
    |
    Dec 1, 2020
    According to a recent New York Times article, the current pandemic in the United States has created an uptick in the number of citizens applying for dual citizenship in other areas of the world. With a focus on Europe, the author of the article notes that the laws for obtaining citizenship in European countries are favorable to those descended even several generations from their original ancestor immigrants.

  • Use It or Lose It: Income Tax Attributes at Death

    By:
    Carl Fiore, JD, LLM
    |
    Oct 1, 2020

    With potential reductions in the gift, estate, and generation-skipping transfer tax exemptions looming, many practitioners are rightfully focused on planning with these exemptions. However, as part of this planning, it’s also important to not lose focus on income tax attributes.

  • Important FAQ: Section 166

    By:
    Robert M. Finkel
    |
    Oct 1, 2020

    These days, many of our clients are holding debt obligations they can’t collect. The IRC may provide some relief, in the form of a tax deduction or loss, for creditors holding a worthless (or in some cases even a partially worthless) bona fide debt, provided that conditions set forth within IRC section 166 and the related Treasury Regulations are satisfied.

  • Restructuring and Repurchasing Distressed Debt: Risks and Opportunities for Borrowers

    By:
    Todd Hatcher, Esq.
    |
    Sep 1, 2020
    Amid an almost unprecedented (in the modern era) pandemic, debt restructuring and workout transactions are accelerating. Similarly, dislocations in the debt markets have presented and continue to present opportunities for relatively well-situated borrowers or their affiliates to capitalize on substantial discounts.
  • Important FAQs: Cancellation of Debt

    By:
    Robert M. Finkel
    |
    Aug 1, 2020
    In the current economic climate, many of our clients have or will reach agreements with creditors to reduce agreed debt. The reduction of certain types of debt can give rise to taxable income to the debtor, so-called cancellation of debt (COD) income under IRC section 61(a)(12).
  • IRS Notice 2020-39: Additional Opportunity Zone Relief Due to the COVID-19 Pandemic

    By:
    Kevin Matz, Esq., CPA, LLM
    |
    Aug 1, 2020

    In an effort to extend additional relief to opportunity zones in light of the COVID-19 pandemic, the IRS issued Notice 2020-39 on Jun. 4, 2020. It provides very significant relief for qualified opportunity funds (QOF) and their investors.

  • Tax Reform, the CARES Act, and Beyond: Hedge Fund Schedule K-1 for Individuals

    By:
    Suzy Lee, CPA, MST, and Stacy L. Palmer, CPA, MBA, MST
    |
    Jul 1, 2020
    In 2016, the authors’ article, “Deconstructing Hedge Fund Schedule K-1s for Individuals,” was published in the TaxStringer. It discussed hedge fund schedules K-1—but much has changed since then. This discussion will review how such changes have affected the presentation of hedge fund K-1s. 
 

 
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.