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Federal Taxation

  • A Practical Discussion with Respect to Internal Revenue Code Section 1031—The "Like Kind" Tax-deferred Exchange, Part 3

    By:
    Raymond L. Liebman, Esq., CPA
    |
    Apr 1, 2024

    This is the final part of a three-part series explaining the basics of the tax-deferred 1031 exchange, the different types available, the mechanics of how they work, and the benefits to be reaped by a client who decides to partake in such an exchange. To view Part 1, please click here. To view Part 2, please click here.

  • Getting Back to Basics: Securities Analysis and Section 475 Elections

    By:
    Brandon Blitzer, CPA and Edward Weissman, CPA
    |
    Apr 1, 2024
    In the dynamic world of financial markets, investors and traders employ various strategies to maximize returns and manage risks. However, these strategies often come with complex (at times, costly) tax implications that can significantly affect the taxable income reported. Understanding the common tax adjustments that arise from trading in the financial markets (e.g., wash sales, straddle adjustments, constructive sales) and the methods to remedy or control the amount of the adjustments are key to a tax-efficient trading strategy.
  • A Practical Discussion with Respect to Internal Revenue Code Section 1031—The "Like Kind" Tax-deferred Exchange, Part 2

    By:
    Raymond L. Liebman, Esq., CPA
    |
    Mar 1, 2024

    This is the second part of a three-part series explaining the basics of the tax-deferred 1031 exchange, the different types available, the mechanics of how they work, and the benefits to be reaped by a client who decides to partake in such an exchange. To view Part 1, please click here.

  • Considerations of S-Corp Acquisitions

    By:
    Thomas Mitchell, Esq., and Brian Krastev, Esq.
    |
    Jan 3, 2024
    When buying or selling a business, the existence of a target company that is taxed as a subchapter S corporation (an “S Corporation”) can be advantageous for all parties to a transaction. The acquisition of an S Corporation, however, presents unique tax considerations that are vital for both buyers and sellers to understand.
  • Proposed Bipartisan Legislation on Opportunity Zones and Qualified Opportunity Funds Would Extend the Investment and Gain Deferral Period By Two Years and Permit Investment in a Fund of Funds

    By:
    Kevin Matz, Esq., CPA, LLM
    |
    Dec 1, 2023

    On September 27, 2023, H.R. 5761, the “Opportunity Zones Transparency, Extension and Improvement Act,” was introduced as bipartisan legislation in the House of Representatives (the “proposed legislation”).[1]  Among other things, the proposed legislation, if enacted into law, would extend the investment and tax deferral period for capital gains that are invested in qualified opportunity funds (QOFs) by two years (from December 31, 2026 to December 31, 2028) and permit QOFs to be structured as a fund of funds.

  • Recent Court Decision Highlights the Split in Authority Concerning the Estate Tax Treatment of Life Insurance under a Buy-Sell Agreement

    By:
    Kevin Matz, Esq., CPA, LLM
    |
    Oct 1, 2023
    In Connelly v. United States, No. 21-3683 (8th Cir. 2023), the United States Court of Appeals for the Eighth Circuit, on the taxpayer’s appeal from an order granting summary judgment in favor of the IRS by the United States District Court for the Eastern District of Missouri, considered(i) whether a buy-sell agreement was able to fix the value of the decedent’s corporate shares for estate tax purposes (it was not), and (ii) whether life insurance proceeds payable to the corporation to help fund a corporate redemption of shares needed to be considered in determining the fair market value of the corporate shares for federal estate tax purposes.
  • Recent Tax Court Case Contains Detailed Discussion of Gift Tax Adequate Disclosure Requirements

    By:
    Kevin Matz, Esq., CPA, LLM
    |
    Sep 1, 2023

    Schlapfer v. Commissioner, T.C. Memo. 2023-65 (U.S. Tax Court May 22, 2023), is the first reported case to contain a detailed discussion of the adequate disclosure requirements under the gift tax adequate disclosure regulations that are set forth in Treas. Reg. Sec. 301.6501(c)-1(f).

     

 

 
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.