Latest Articles

  • A Review of Two Key Provisions of the Taxpayer First Act

    By:
    Frank G. Colella, Esq, LLM, CPA
    |
    Dec 1, 2019
    The Taxpayer First Act (TFA), signed into law on July 1, 2019, established the new IRS Independent Office of Appeals. While most of the new provisions simply formalized current Appeals practice and procedure, the TFA specifically codified [in the new IRC section 7803(e)] the right to an IRS appeal when a taxpayer has received a statutory notice of deficiency, commonly referred to as the 90-day letter.
  • Qualified Opportunity Zones: A Family Office Perspective

    By:
    Shashi Singal, CPA, MSA, CA
    |
    Dec 1, 2019
    Family offices, in their role as wealth-management advisors, are tasked with educating families and presenting them with the most tax-efficient options for transferring wealth, while also taking into consideration the lifestyle needs of the family. One area of interest and concern to family offices are Qualified Opportunity Zones (QOZ), as well as businesses located in such areas and Qualified Opportunity Funds (QOF).
  • A Case of New York State Statutory Residency

    By:
    Brian Gordon, CPA
    |
    Dec 1, 2019

    A case concerning New York State statutory residency for the years 2012 and 2013 was recently decided by an Administrative Law Judge (ALJ) in the matter of Nelson Obus. This case reveals specifics of the law surrounding statutory residency, and how that law can potentially trip up taxpayers.

  • Carrying the Day with Carried Interest Wealth Transfer Planning for Fund Principals

    By:
    N. Todd Angkatavanich, JD, LLM, Joel Friedlander, JD, Joshua Zimmerman, JD, LLM, and Naomita Yadav, JD
    |
    Dec 1, 2019

    As the financial markets flourish, there continues to be a strong focus on gift and estate planning opportunities available to hedge fund and private equity fund managers. The inherent compensation structure, including the “carried interest,” presents a unique opportunity for advisors to formulate wealth-transfer strategies for the fund manager’s future generations.

  • The Latest Proposals on Qualified Opportunity Zone Businesses

    By:
    Michelle M. Jewett, JD, Kevin Matz, JD, Esq., CPA, LLM, Jeffrey D. Uffner, JD, LLM (taxation), Richard Madris, JD, and David C. Olstein, JD
    |
    Nov 1, 2019
    The new tax incentive added by the 2017 Tax Cuts and Jobs Act—designed to promote long-term growth in economically distressed areas known as qualified opportunity zones (QOZ)—is gaining interest among businesses and business owners interested in starting or expanding businesses in QOZs or moving existing businesses to QOZs.
  • Guidance for Transferees of Partnership Interests

    By:
    Christine Piar, Managing Director of Deloitte Tax, LLP, Copyright © 2019 Deloitte Development LLC
    |
    Nov 1, 2019
    On May 7, 2019, the IRS and the U.S. Treasury department released Proposed Regulations under IRC section 1446(f) that potentially have broad application to the transfer of any partnership interest. It’s important that transferees understand in what manner and to what extent the withholding provisions could apply to them, as well as the potential consequences of noncompliance. This article focuses specifically on the effect of these regulations on the transferee of nonpublicly traded partnership interests, even when withholding does not apply.
  • Skilled Versus Custodial Care for Senior Citizens

    By:
    Daniel G. Fish
    |
    Nov 1, 2019

    Like a wheel of fortune, some senior citizens will suffer an illness and no financial risk, whereas others will suffer both an illness and a financial exposure. And many senior citizens are completely unaware of the hidden financial risk they face.

  • Taxation of Carried Interests for Senior-Level Fund Managers

    By:
    Arthur H. Kohn, Andrew L. Oringer, and Steven W. Rabitz
    |
    Oct 1, 2019
    Carried interest arrangements have been common for years in many types of private investment funds (“Funds”), including private equity, real estate, and hedge funds. Going back a few decades, the tax analysis applicable to carried interests was highly uncertain. 
  • IRS and Cryptocurrency: Where are We Now and What Next?

    By:
    Melissa Gillespie, JD, CPA, MST
    |
    Oct 1, 2019
    Over the past few years, the IRS has been slowly issuing guidance and warnings regarding the reporting and taxation of the usage and exchanging of virtual currency. Recently, on July 26, 2019, the IRS advised those who have engaged in virtual currency usage that they have begun sending educational letters to taxpayers with virtual currency transactions who either may have failed to report income and pay the resulting tax from virtual currency transactions or did not report their transactions properly.
  • The Case for the Continuing Relevance of the Gift Tax

    By:
    Philip A. Di Giorgio, Esq.
    |
    Oct 1, 2019

    With the passage of the Tax Cuts and Jobs Act of 2017 (the 2017 Tax Act) the lifetime exemptions from estate, gift and generation skipping transfer tax (GST) more than doubled from an already steep $5,490,000 to a cliff-hanging $11,180,000 as of January 1, 2018. As in the past, these exemption amounts continue to be adjusted for inflation leaving us with a gift tax exemption of $11,400,000 as of January 1, 2019. New York State repealed its gift tax back at the turn of the millennia, so the gift tax is strictly a federal phenomenon for New Yorkers.

Tax Quote
 

"Government's view of the economy could be summed up in a few short phrases: If it moves, tax it. If it keeps moving, regulate it. And if it stops moving, subsidize it."

 – Ronald Reagan

*Outside the Box is a new addition to the TaxStringer featuring important articles on financial and investment management topics by top authors who have expertise both inside and outside the realm of taxation.

 

 

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