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Federal Taxation

  • SCOTUS Addresses Constitutional Challenge to Mandatory Repatriation Tax

    By:
    Gary Forester, JD, LLM
    |
    Dec 1, 2024

    In Moore v. U.S. (36 F. 4th 930), the U.S. Supreme Court ruled on a constitutional challenge of IRC section 965, the mandatory repatriation tax (MRT). The MRT is a one-time repatriation tax (or “deemed dividend”) that passes through undistributed accumulated income of U.S.-controlled foreign corporations (CFCs). Section 965 is part of the 2017 Tax Cuts and Jobs Act (P.L. 115-97), which addresses foreign business earnings, including CFCs, inversions and the GILTI tax. The Act generally taxes U.S. shareholders owning 10% or more of a foreign corporation on otherwise tax-deferred foreign earnings.

  • The Sunset of the Doubled Estate, Gift, and GST Tax Exclusion Amounts after December 31, 2025 – What High Net Worth Individuals and Family Offices Need to Know About It

    By:
    Lucy D. Bickford and Kevin Matz, CPA, JD, LLM
    |
    Nov 1, 2024
    In the world of high-net-worth individuals and their financial advisors, the sunset of certain provisions of the 2017 Tax Cuts and Jobs Act (TCJA) is a topic of intense discussion. The TCJA significantly increased the lifetime gift and estate tax exclusion and the generation-skipping transfer (GST) tax exemption. 

  • Charitable Planning for Individuals

    By:
    Sahri Zeger, JD
    |
    Oct 1, 2024

    Charitable contributions play a crucial role in addressing important needs within our communities, and the U.S. tax code recognizes their value by providing various incentives. By understanding tax strategies related to charitable giving, individuals can maximize their impact while also receiving significant tax advantages. This article will discuss some lesser-known aspects of direct charitable giving and common charitable planning strategies using trusts.

  • The U.S. Supreme Court Affirms the Eighth Circuit’s Decision in Favor of the Government Concerning the Estate Tax Treatment of Life Insurance Proceeds Used to Fund a Corporate Redemption Obligation

    By:
    Kevin Matz, CPA, JD, LLM
    |
    Aug 1, 2024
    In Connelly v. U.S., 602 U.S. ___ (6/6/2024), the United States Supreme Court affirmed a decision of the Eighth Circuit Court of Appeals in favor of the government concerning the estate tax treatment of life insurance proceeds that are used to fund a corporate redemption obligation under a buy-sell agreement. The specific question presented was whether, in determining the fair market value of the corporate shares, there should be any offset to take into account the redemption obligation to the decedent’s estate under a buy-sell agreement. 

  • Penalties in Modern Tax Practice

    By:
    Melissa Wiley
    |
    Jun 3, 2024

    “In 1955, there were approximately 14 penalty provisions in the Internal Revenue Code. There are now [in 2011] more than ten times that number.”  Internal Revenue Manual (“IRM”) part 20.1.1.1.1.

    Whenever I am asked why it is that I speak so often about penalties, I highlight the above quote from the IRS’s employee handbook. Whereas there were 14 penalty provisions in 1955, approximately 150 were listed by 2011; there are even more now, 13 years later.

  • The YA Global Tax Court Decision: Private Fund Activities Drag Non-U.S. Fund Investors Into the U.S. Tax Net

    By:
    Mark Leeds
    |
    Jun 3, 2024
    For U.S. history aficionados, November 15 is an auspicious day: It was on this day in 1777 that the Continental Congress approved the Articles of Confederation. These articles framed the basic form of government for what was to become the United States. Well, tax folks working with private funds are likely to remember November 15 for another reason as well. 

  • Nothing to Fear but Fear Itself: Planning in the Current Environment

    By:
    Carl Fiore, JD, LLM
    |
    May 1, 2024
    As the calendar turns to 2024, taxpayers and their advisors face an uncertain future.  Given a divided government for at least the next two years, it is not the usual suspect of potential legislation and sweeping tax changes that fuels this uncertainty. Instead, a declining market, the potential for recession looming, and increasing interest rates has left many taxpayers in a general malaise heading into the new year. However, while this overall economic downturn presents at least short-term challenges, it also creates certain wealth planning opportunities.
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