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Federal Taxation

  • Lifetime Gifts and Testamentary Transfers by US Grantors to Non-Citizens

    By:
    Gary Forster, JD, LLM
    |
    Dec 1, 2025
    The US estate and gift tax is imposed on lifetime gifts and the “gross estate” of US citizens and domiciliaries (residents who intend to stay in the US indefinitely). The gross estate of a US person includes “the value at the time of death of all property, real or personal, tangible or intangible, wherever situated.” The estate and gift taxes attach to all assets regardless of the location of the US citizen or resident (or his property) at the time of gift or death.

  • Qualified Small Business Stock (QSBS): A Powerful Tax Break

    By:
    Andrew S. Katzenberg, JD, LLM, and Miguelina Mercedes, JD
    |
    Nov 1, 2025
    Few provisions of the Internal Revenue Code (the "Code") are as generous as the rules under section 1202 governing "qualified small business stock," most commonly known as QSBS. Designed to encourage investment in start-ups, section 1202 permits capital gain exclusion on all or a portion of the sale proceeds of QSBS in C corporations.

  • IRS Form 990: What Executives And the Board Should Evaluate

    By:
    By Zachary Segal, MST and Lori Rothe Yokobosky, MST
    |
    Nov 1, 2025
    While the IRS Form 990, “Return of Organization Exempt from Income Tax,” is often viewed as a routine compliance requirement, its impact and audience reach far beyond tax reporting and the IRS. For nonprofit organizations, this form can serve as a powerful public-facing tool that shapes perceptions of governance, transparency, and financial stewardship. 

  • Navigating the 2024 Form 6765 Overhaul: Key Insights for R&D Credit Practitioners

    By:
    Akshay Shrimanker, CPA, and Jay Persaud, CPA
    |
    Oct 1, 2025
    On Jun. 12, 2025, the NYCPA C-Corporation Tax Committee hosted a one-hour CPE to unpack the IRS’s comprehensive redesign of Form 6765, Credit for Increasing Research Activities, better known as the R&D Tax Credit form.

  • QOZ Planning Under the OBBBA

    By:
    Kevin Matz, CPA, JD, LLM
    |
    Sep 4, 2025
    On Jul. 4, 2025, President Trump signed into law the One Big Beautiful Bill Act,  formally known as H.R.1 – An Act to provide for reconciliation pursuant to title II of H. Con. Res. 14 (the OBBBA). The OBBBA includes provisions that establish a “second tranche” for the Qualified Opportunity Zone (QOZ) and qualified opportunity fund (QOF) program that is generally effective beginning Jan. 1, 2027.

  • Interim Guidance Simplifies Application of the Corporate Alternative Minimum Tax to Partnerships

    By:
    Aaron Lebovics, CPA, Annet Thomas-Pett, CPA, Charwin Embuscado, CPA, Jason Black, CPA, Michael Hauswirth, JD, Craig Gerson, JD, LLM, Corey Dalton, CPA, and Brett York, JD
    |
    Sep 4, 2025
    On Jul. 29, 2025, Treasury and the IRS issued Notice 2025-28 (the Notice) indicating their intent to partially withdraw proposed Corporate Alternative Minimum Tax (CAMT) regulations related to partnerships. The Notice also provides interim guidance to simplify CAMT’s application to partnerships. Forthcoming proposed regulations will include rules similar to the interim guidance provided in the Notice. 

  • First Look at the Tax Provisions of “The One Big Beautiful Bill Act”: How It Affects Individuals

    By:
    Mark H. Levin, CPA, MS (Taxation)
    |
    Aug 1, 2025

    On Jul. 4, 2025, President Trump signed The One Big Beautiful Bill Act (OBBBA) into law as Public Law 119-21. Title XI of the law contains the tax provisions for the 2025–2026 federal budget.
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