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Latest Articles

  • A Tale of Two Citizenships: Taxation of American Citizens with Dual Citizenship Living Abroad

    By:
    Alicea Castellanos, CPA
    |
    Dec 1, 2020
    According to a recent New York Times article, the current pandemic in the United States has created an uptick in the number of citizens applying for dual citizenship in other areas of the world. With a focus on Europe, the author of the article notes that the laws for obtaining citizenship in European countries are favorable to those descended even several generations from their original ancestor immigrants.

  • Common Cryptocurrency Frauds

    By:
    Katerina L. Gaebel, CPA, CFE
    |
    Dec 1, 2020

    Bitcoin was first introduced to the world in 2009 after the global economic crisis. Bitcoin developers wanted to empower individuals to initiate online transactions that are anonymous, fast, irreversible, secure, and without the involvement of a third party. Although Bitcoin was not created to condone malicious conduct, fraudsters often use cryptocurrency because of its semi-anonymous nature.

  • Stuck in the Middle with You: The Rise of the Independent Sponsor in the Middle and Lower Middle Market

    By:
    Paul Marino, JD
    |
    Dec 1, 2020
    The independent sponsor (formerly known as “fundless sponsors”) is an equity sponsor that seeks to purchase (generally) privately held business with the backing of investors.  However, as opposed to private equity funds, independent sponsors do not have access to pooled cash reserves and therefore must seek investors on a deal-by-deal basis.
  • Remote Workers Beware: Potential Double Taxation Under the Convenience Rule

    By:
    Ariele R. Doolittle, Esq.
    |
    Nov 1, 2020

    As the realities of COVID-19 are setting in, telecommuting arrangements have emerged as part of the new normal. A recent study found that the vast majority of employers plan to allow their employees to work remotely at least part-time and nearly half will allow this full-time going forward. Remote workers utilizing new work locations can trigger state-level income tax consequences, which may include two states seeking to tax the same income.

  • Final Regulations Applying the High-Tax Exclusion to Global Intangible Low-Taxed Income

    By:
    Timothy Larson, CPA
    |
    Nov 1, 2020

    The IRS recently issued final and proposed IRC section 951A regulations relating to the treatment of “high-taxed” global intangible low-taxed income (GILTI), introduced in 2017 by the Tax Cuts and Jobs Act (TCJA). This latest guidance is welcome news to many U.S. investors, who may now make annual elections to exclude high-taxed GILTI from their gross income — both going forward and retroactively to 2018.

  • 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.
Tax Quote
  

"The best things in life are free, but sooner or later the government will find a way to tax them."

 –  Anonymous

*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.