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Code Section 754: Allocating Gain Where it Belongs

Our Recommended Reading List on Tax Policy

Nothing to Fear but Fear Itself: Planning in the Current Environment
Final Subpart F Regulations and Domestic Partnership Tax Reporting
A Year in Review and an Outlook on the Horizon for Tax-Exempt Entities

Latest Articles

  • A Spotlight on New York State Residency Requirements

    By:
    Mark A. Nickerson, CPA, CMA, MBA
    |
    Jan 1, 2020
    In October 2019, President Donald Trump became the most recent high-profile individual to announce his departure from New York, choosing to make Florida his place of permanent residence. The move is heavily, if not entirely, motivated by the fact that Florida does not have any personal income or estate tax, whereas New York’s top income tax rate is 8.82% (and even higher for individuals living in New York City) and the top estate tax rate is 16%.

  • Excess Benefit Transactions

    By:
    Magdalena M. Czerniawski, CPA, MBA, and Robert Lyons, CPA, MST
    |
    Jan 1, 2020
    Excess benefit transactions (EBT) are an outgrowth of IRC section 4958, which was first introduced in 1996 and modified in 2003. Its purpose was to punish the wrongdoer but not necessarily revoke the exemption of what may be a perfectly good charitable organization with bad management.

  • 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. 
Page

Tax Cases


In Case You Missed It – May 2023
Tax Jokes
  

Which Avenger pays the least taxes? Spider-Man, because his income is all net.

https://parade.com/1317763/jessicasager/accounting-jokes/

Tax News


IRS, Other Agencies Issue COVID-19 FAQs in Response to Impending End of Public Health Emergency,The Trusted Professional

Tax Court Rules IRS Does Not Have Statutory Authority to Assess Penalties for Failure to File Form 5471,Forbes Media LLC

IRS Revises Guidance on Bitcoin, in Light of Its Use As Legal Tender in Some Nations,The Trusted Professional

Hight Court Considering Case on Whether IRS Can Secretly Obtain Bank Records of Taxpayer's Relatives,The Trusted Professional

More Foreign Companies Than Expected May Be Subject to 1% Buyback Tax,The Trusted Professional

After Beyoncé Failed to Work It Out With IRS, She Filed A Petition in Tax Court,Forbes Media LLC

*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.