Latest Articles

  • 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.

  • Final Regs. on Deduction of Administration Expenses of Estates and Non-Grantor Trusts

    By:
    Kevin Matz, Esq., CPA, LL.M. (Taxation)
    |
    Nov 1, 2020

    On September 16, 2020, the U.S. Department of Treasury (“Treasury”) and the IRS released final regulations on the deduction of administration expenses of estates and non-grantor trusts under sections 67(e) and (g), and on the treatment of excess deductions in the final year of the estate or non-grantor trust under section 642(h) (the “final regulations”).

  • Demystifying Tax Insurance

    By:
    Scott Brady, Mark McTigue, CPA, MBA, Antony Joyce, Alisha Soares, JD
    |
    Nov 1, 2020

    Tax planning can be complex. It must balance tax efficiency with all other elements of financial planning required to meet a company’s commercial objectives. Most importantly, tax planning and tax structuring strategies need to withstand the scrutiny of a taxing authority.

  • 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.

  • 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.
  • Interest Rates and Planning: What You Need to Know

    By:
    Blanche Lark Christerson, JD, LLM (taxation)
    |
    Oct 1, 2020

    Interest rates are at historic lows. This is good news for certain planning techniques and bad news for others.   

    Specifically, low interest rates work extremely well if an estate “freeze” technique involves an annuity or a loan and work poorly if a freeze technique involves income and reversionary interests. In other words, low interest rates make this a good time for grantor retained annuity trusts (GRATs), sales to “defective” grantor trusts (Sales) and charitable lead annuity trusts (CLATs), but a bad time for qualified personal residence trusts (QPRTs) and charitable remainder annuity trusts (CRATs).
  • “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.

10 Years of TaxStringer Stats

Thank you, our readers, for your ongoing interest in the TaxStringer and contributing to its 10-years of success. We thought we could provide you with some interesting statistics from the 10-year history (October 2010-September 2020) of the TaxStringer. Read here.


Tax Quote
  

"Elections should be held on April 16th- the day after we pay our income taxes. That is one of the few things that might discourage politicians from being big spenders."

 – Thomas Sowell

*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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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.