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State Taxation

  • Stuck in the Middle with You: The Rise of the Independent Sponsor in the Middle and Lower Middle Market

    By:
    Paul Marino, JD
    |
    Dec 1, 2020
    The independent sponsor (formerly known as “fundless sponsors”) is an equity sponsor that seeks to purchase (generally) privately held business with the backing of investors.  However, as opposed to private equity funds, independent sponsors do not have access to pooled cash reserves and therefore must seek investors on a deal-by-deal basis.
  • Remote Workers Beware: Potential Double Taxation Under the Convenience Rule

    By:
    Ariele R. Doolittle, Esq.
    |
    Nov 1, 2020

    As the realities of COVID-19 are setting in, telecommuting arrangements have emerged as part of the new normal. A recent study found that the vast majority of employers plan to allow their employees to work remotely at least part-time and nearly half will allow this full-time going forward. Remote workers utilizing new work locations can trigger state-level income tax consequences, which may include two states seeking to tax the same income.

  • Final Regulations Applying the High-Tax Exclusion to Global Intangible Low-Taxed Income

    By:
    Timothy Larson, CPA
    |
    Nov 1, 2020

    The IRS recently issued final and proposed IRC section 951A regulations relating to the treatment of “high-taxed” global intangible low-taxed income (GILTI), introduced in 2017 by the Tax Cuts and Jobs Act (TCJA). This latest guidance is welcome news to many U.S. investors, who may now make annual elections to exclude high-taxed GILTI from their gross income — both going forward and retroactively to 2018.

  • Structuring the Deal: Taxation When Selling Your Financial Service Business

    By:
    David Grau Jr., MBA, and Nicole Frey, CFP
    |
    Oct 1, 2020
    For professionals planning to purchase or sell a financial services book of business, the most common negotiating points are the purchase price, deal structure, timeline, and financing considerations. These are critical points to discuss and finalize before signing on the dotted line.
  • “Quarantining" in the States: Tax Residence Issues During the COVID-19 Pandemic

    By:
    Scott S. Ahroni, JD, LLM (taxation)
    |
    Sep 1, 2020

    The global outbreak of COVID-19 has significantly impacted individuals and their ability to travel. Many are under state quarantine orders, “sheltering in place,” or simply afraid or uncomfortable to leave their home. Other individuals have left their home in one state for the prospect of a safer, more socially distant location in another state or country. 

  • Give Me Your Tired, Your Poor…and Your Tax Planners? Pre-Immigration Tax Planning for the Hong Kong Emigrant

    By:
    Alicea Castellanos, CPA
    |
    Sep 1, 2020

    At the foot of the Statue of Liberty is an inscribed plaque with a poem about America being the land that welcomes the refugee. Film footage from the turn of the 20th century depicts ships overloaded with immigrants passing the statue and dreaming of a better tomorrow in the United States.

  • Examining Emerging Technologies After COVID-19: Tax, Accounting, and Artificial Intelligence

    By:
    Adrien Luther
    |
    Sep 1, 2020

    As we continue to adjust to the impact of the COVID-19 crisis and rethink how business gets done, it’s important to realize how far we’ve come in this short amount time. Managing through this pandemic has allowed us to adapt and stretch our creativity to safeguard business continuity and exhibit resiliency. For many of us, technology was at the forefront of our ability to continue moving forward—or, at the very least, not move backward.

 
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.