• “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. 

  • 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.
  • 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.

  • 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.

  • Asset Protection Planning for Vulnerable Professionals

    By:
    Matthew E. Rappaport, JD, Esq., LLM
    |
    Aug 1, 2020

    America is the most litigious society in the world, and few thoughts strike more fear into the hearts of ordinary people than a protracted lawsuit and—even worse—enforcement of a monetary judgment. Outside of the nation’s capital, New York is home to the most lawyers per capita, so the dangers of litigation loom larger in that state than almost anywhere else.

  • How Joseph Wilson Escaped the Clutches of the IRS and Its Form 3520 Penalties

    By:
    Alicea Castellanos, CPA
    |
    Aug 1, 2020

    Even if you’re not a classic film buff, you may know of the “damsel in distress” film genre from the era of silent movies: A villain decked out in a curlicue mustache kidnaps a pretty woman—the significant other of his archenemy—and ties her to the railroad tracks. As the train comes clickety-clacking down the track, the hero, a handsome man on a white horse, rescues the damsel in the nick of time. He also captures the villain and saves the day.

  • 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. 
  • A Simple Fix to the “Retail Glitch”

    By:
    Luke Richardson, CPA, MAcc, and John McKinley, CPA, CGMA, JD, LLM
    |
    Jul 1, 2020

    With the recent passage of the Coronavirus Aid, Relief, and Economic Security (CARES) Act, Congress enacted many tax provisions intended to lessen the economic harm caused by the coronavirus (COVID-19) outbreak. Among those changes was a fix for an issue known as the “retail glitch,” which arose from the last major piece of tax legislation, the Tax Cuts and Jobs Act (TCJA).

  • Helpful Instructions for Filing Domestic and Foreign Voluntary Disclosures

    By:
    Ellen S. Brody, JD, CPA, Esq., and David J. Snyder, JD
    |
    Jul 1, 2020

    In April 2020, the IRS quietly updated Form 14457. Previously called the “Offshore Voluntary Disclosure Letter,” the form’s name was changed to “Voluntary Disclosure Practice Preclearance Request and Application.” It had been used in conjunction with the Offshore Voluntary Disclosure Program (OVDP) that ended Sept. 28, 2018.

  • Can New York State Audit Federal Tax Issues?

    By:
    Brian Gordon, CPA
    |
    Jul 1, 2020

    In a typical case, the IRS will audit federal tax issues, and when audit changes are made, it will notify New York State. With little additional work, New York will bill the taxpayer the amount of additional state tax resulting from these federal tax changes. Taxpayers are required to report the IRS audit changes on a New York State amended return within 90 days of the IRS notification, regardless of whether they receive a bill from the state.

  • Protecting Yourself, Your Family, and Your Heirs during the COVID-19 Crisis

    By:
    Kevin Matz, Esq, CPA, LLM
    |
    Jun 1, 2020
    We live in unprecedented times. Many of the tenets we thought we knew at the beginning of March 2020 have now been shattered by COVID-19, which has wreaked havoc not only on our nation’s public health but also on the worldwide economy and the financial markets. 
  • Coronavirus and Nonprofits: Cancellation of Fundraising Events and Membership Dues May Convert to Tax-Deductible Donations

    By:
    Eva Mruk, Susan Barossi, CPA , and Garrett M. Higgins
    |
    Jun 1, 2020
    In the wake of the coronavirus (COVID-19) pandemic, charitable organizations around the world have been forced to cancel or postpone their fundraising events. In addition, many charitable organizations have been advised to close their facilities and perform their operations virtually, if possible. As a result, nonprofits that collect membership dues, tuition, or fees can render limited or even no services in exchange.
  • New PTIN User Fee: IRS Announcement Despite Ongoing Remand Litigation

    By:
    Frank G. Colella, Esq, LLM, CPA
    |
    Jun 1, 2020
    The IRS recently announced its intention to reimpose a practitioner tax identification number (PTIN) user fee for the 2020 tax season. The proposed regulation requires tax practitioners to pay $21 (plus a vendor fee) to obtain or renew their PTINs.
  • Equity and Equity-Based Compensation for LLCs

    By:
    Robert M. Finkel
    |
    Jun 1, 2020
    The structures for granting equity incentives to employees and other service providers of corporations are tried and true. The income tax consequences to a grantee upon his receipt of restricted stock and stock options and to the issuing corporations are well settled.
  • COVID-19 Emergency Tax Postponement Relief: The IRS Expands Its Scope

    By:
    Kevin Matz, JD, Esq., CPA, LLM
    |
    May 1, 2020
    On Apr. 9, 2020, as a further response to COVID-19, the U.S. Treasury Department and the IRS issued Notice 2020-23, which significantly expanded the scope of the emergency tax postponement relief. The relief granted by the new notice covers taxpayers who have an IRS tax filing or payment deadline between Apr. 1 and Jul. 15, 2020.
  • Estate Planning for Founders and Investors in Venture-backed Companies: Transfers of Qualified Small Business Stock by Gift

    By:
    Michael S. Arlein and Brian M. Sweet
    |
    May 1, 2020
    Congress first enacted IRC section 1202 in 1993 to encourage investment in specific types of small businesses by providing an exclusion of certain gain from the sale or exchange of qualified small business stock (QSBS). The original benefits of IRC section 1202 attracted moderate attention, but those benefits were significantly enhanced in subsequent decades, most notably under the Small Business and Jobs Act of 2010.
  • Penalty Avoidance: When Can Taxpayers Rely on Their Advisors?

    By:
    Ellen S. Brody, JD, Esq., CPA and Menahem M. Grossman, Esq.
    |
    May 1, 2020
    The IRC imposes various penalties on taxpayers who fail to comply with the obligations it sets forth for them. However, taxpayers can often avoid penalties if they can prove that their failure was due to reasonable cause and that they acted in good faith [IRC section 6664(c)(1)].
  • Tax Exemption: What Nonprofit Executives, Board Members, and Auditors Need to Know (Part 2 of 2)

    By:
    Allen L. Fetterman, CPA, MBA
    |
    May 1, 2020
    Published in the April issue of TaxStringer, part 1 of this series provided a beginning overview of the basics of tax exemption. This article will continue that discussion, focusing especially on tax exemption with respect to jeopardizing tax-exempt status, lobbying, the Form 990 series, and state laws.

 
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