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Income Taxation

  • Powerful Domestic Trust Strategies for International and Cross-Border Families

    By:
    Al W. King III, JD, LLM (tax law) and Jack R. Brister
    |
    May 1, 2018
    There has been a powerful evolution taking place over the last decade of international families utilizing the United States for their trusts. Previously, the main reasons for an international family to establish a U.S. situs trust were if they owned U.S. property or if they had a U.S. green card or U.S. citizen family members. 

  • Social Security Filing Strategies Under the New Rules

    By:
    Ash Ahluwalia, MBA, CFP
    |
    May 1, 2018

    For most Americans, social security retirement benefits typically represent 30 to 60% of their retirement income. Yet according to the National Social Security Association, LLC, over 90% of social security recipients receive less money than they are entitled to receive. For many filers, this can represent tens of thousands of dollars in lost retirement benefits.

  • Self-Employment Tax for Partnerships, LLC and LLP Members

    By:
    Dean L. Surkin, JD, LLM
    |
    Apr 1, 2018
    The advent of the Tax Cuts and Jobs Act of 2017 has started to affect the entity structures that taxpayers choose for their businesses. Some practitioners are recommending an expanded use of C corporations while others are recommending maximum utilization of the qualified business income (QBI) deduction. 

  • With Tax Reform Uncertainty, Roth Conversions Need a Tremendous Amount of Confidence

    By:
    David M. Barral, CPA/PFS, CFP
    |
    Dec 1, 2017
    Tax reform has been on every tax professional’s mind—even more so as we approach year-end. Without any certainty of where we’re heading and when any changes will take effect, tax planning for clients has become increasingly difficult. It is a particularly difficult decision for those contemplating a Roth conversion, which can carry with it a hefty tax bill. 

  • Information Exchange With the United Kingdom Leads to Adjustment in Foreign Tax Credit Claimed

    By:
    Charles Ladas, CPA, and Joseph Neri, CPA
    |
    Oct 1, 2017
    As the global economy becomes more aligned, it is common for businesses and individuals today to have income and tax compliance issues in more than one country. With the complexity of varying tax regimes and the difficulty in monitoring offshore tax compliance, governments and taxing authorities around the world are looking for ways to collaborate and ensure taxpayers are paying their fair share, wherever they may be. 

  • Issues in Sun Capital Continue to be Top of Mind for Investment Funds

    By:
    LD Sergi
    |
    Jun 1, 2017

    In March 2016, the federal district court in Massachusetts (the “District Court”), issued a decision in Sun Capital Partners III, LP v. New England Teamsters & Trucking Industry Pension Fund, 2013 U.S. App. LEXIS 15190 (1st Cir. 2013) (“Sun Capital”), holding that, for purposes of pension withdrawal liability under Title IV of the Employee Retirement Income Security Act of 1974 (ERISA), as amended by the Multiemployer Pension Plan Amendment Act of 1980 (MPPAA), two private equity funds were engaged in a trade or business and that they were under “common control” with the portfolio company such that they were jointly and severally liable for its pension withdrawal liability. 

  • Qualified Retirement Plan Design for Closely Held Businesses

    By:
    Andrew E. Roth, Esq., JD, LLM
    |
    May 1, 2017

    The primary goal of most employers in establishing any type of retirement savings program is to provide retirement income in a tax-efficient manner. The best way to achieve this is through a qualified retirement plan.
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