Latest Articles

  • 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.

  • Important FAQs: Cancellation of Debt

    By:
    Robert M. Finkel
    |
    Aug 1, 2020
    In the current economic climate, many of our clients have or will reach agreements with creditors to reduce agreed debt. The reduction of certain types of debt can give rise to taxable income to the debtor, so-called cancellation of debt (COD) income under IRC section 61(a)(12).
  • IRS Notice 2020-39: Additional Opportunity Zone Relief Due to the COVID-19 Pandemic

    By:
    Kevin Matz, Esq., CPA, LLM
    |
    Aug 1, 2020

    In an effort to extend additional relief to opportunity zones in light of the COVID-19 pandemic, the IRS issued Notice 2020-39 on Jun. 4, 2020. It provides very significant relief for qualified opportunity funds (QOF) and their investors.

  • Asset Protection Planning for Vulnerable Professionals

    By:
    Matthew E. Rappaport, JD, Esq., LLM
    |
    Aug 1, 2020

    America is the most litigious society in the world, and few thoughts strike more fear into the hearts of ordinary people than a protracted lawsuit and—even worse—enforcement of a monetary judgment. Outside of the nation’s capital, New York is home to the most lawyers per capita, so the dangers of litigation loom larger in that state than almost anywhere else.

Bonus Article on Federal Taxation

The Infrastructure Investment and Jobs Act


Tax Quote
  

"Just taught my kids about taxes by eating 38% of their ice cream."

 – Conan O'Brien

*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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