Latest Articles

  • 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.
  • Give Me Your Tired, Your Poor…and Your Tax Planners? Pre-Immigration Tax Planning for the Hong Kong Emigrant

    By:
    Alicea Castellanos, CPA
    |
    Sep 1, 2020

    At the foot of the Statue of Liberty is an inscribed plaque with a poem about America being the land that welcomes the refugee. Film footage from the turn of the 20th century depicts ships overloaded with immigrants passing the statue and dreaming of a better tomorrow in the United States.

  • Examining Emerging Technologies After COVID-19: Tax, Accounting, and Artificial Intelligence

    By:
    Adrien Luther
    |
    Sep 1, 2020

    As we continue to adjust to the impact of the COVID-19 crisis and rethink how business gets done, it’s important to realize how far we’ve come in this short amount time. Managing through this pandemic has allowed us to adapt and stretch our creativity to safeguard business continuity and exhibit resiliency. For many of us, technology was at the forefront of our ability to continue moving forward—or, at the very least, not move backward.

What do you think will be the biggest issues tax practitioners will face in 2021?


1) PPP forgiveness and deductibility
2) State nexus, residency, and telecommuting issues in the wake of Covid-19
3) Changes to K-1 basis reporting
4) Potential changes from Covid relief legislation or tax reform under the Biden administration
5) Networking/business development in a remote environment

Please submit your choice via the below link: https://www.surveymonkey.com/r/6BMJ9XL

Tax Quote
  

“The crime of taxation is not in the taking it, it’s in the way that it’s spent.”

 – Will Rogers

*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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