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New CFC Rules for 2026: Section 958(b)(4) Restoration and the Foreign Controlled Corporation Provisions
The One Big Beautiful Bill Act: Tax Provisions
Proposed CAMT Guidance May Have Significant Impact on Asset Management

Coast-to-Coast Tax Residency: Comparing New York and California Residency Rules
Beneficial Owner Disclosure Under the New York LLC Transparency Act

Latest Articles

  • Recent IRS Challenges to Grantor Retained Annuity Trusts (GRATs)

    By:
    Kevin Matz, Esq., CPA, LLM
    |
    Aug 1, 2023

    There are two separate significant IRS challenges to grantor retained annuity trusts (GRATs) in the context of ongoing merger negotiations that have garnered considerable attention going back to 2019. 

  • Impact of SECURE 2.0 on Planning for Trusts

    By:
    Steven. B. Gorin CPA, Esq., CGMA
    |
    Aug 1, 2023

    The last two articles the author wrote, Dealing with Proposed Regs under the SECURE Act and Strategy Under the SECURE Act, examined certain strategic issues that CPAs may need to explain to their clients. This article assumes the reader knows those concepts as a base and complements those ideas with planning for long-term second marriages and for trying to minimize fiduciary income tax on IRAs held in trust without necessarily getting IRA distributions out of trust.   

  • No Romance Without Finance

    By:
    Jacalyn F. Barnett, Esq.
    |
    Aug 1, 2023

    Although horrifying tales of on-line romance scam artists swindling the life savings of the lonely are being highlighted on the airwaves, seeing how the love life of a client or his or her children can devastate well-established family businesses is more terrifying—and pervasive.

  • Why U.S. Crypto-Millionaires Should Undertake their Estate Planning and Create Irrevocable Trusts During this Crypto Market Downturn

    By:
    Mikhail E. Lezhnev, Esq., CPA, MBA, LLM (Tax Law)
    |
    Jun 1, 2023
    Cryptocurrencies, such as Bitcoin (BTC) and Ether (ETH), and non-fungible tokens (collectively “Crypto”), in 2022 were down over 70% from their all-time high in 2021. Although this decline is significant, Crypto investors (holders especially) will be quick to point out such declines have happened several times before.

  • U.S. Charitable Organizations: Considerations for International Activities and Operations

    By:
    Lori A. McLaughlin, CPA, PFS, and Toby R. Kerslake, CPA
    |
    Jun 1, 2023
    With expanded exposure to international issues and needs, U.S. charitable organizations continue to look for ways to expand their reach and increase their impact beyond U.S. borders. Whether considering international activities for the first time, or looking to expand activities in multiple foreign jurisdictions, U.S. charitable organizations should consider opportunities to do good in light of significant challenges that can be present when working outside the United States.

  • The Inheritance Tax under IRC §2801

    By:
    Gary A. Forster, JD, LLM
    |
    Jun 1, 2023

    The Heart Act added a new federal  Inheritance Tax on certain lifetime and testamentary dispositions to U.S. recipients, made by a “covered expatriate.” This is the second article in our two-part series on the expatriation tax. (To view the first article, please click here.)

  • 990-PF: Part VI-A Statements Regarding Activities and Part VI-B Statements Regarding Activities for Which Form 4720 May Be Required

    By:
    Jeffry Haber, PhD, CPA
    |
    Jun 1, 2023
    The 990-PF (PF) is an old document that has not had a recent overhaul. A minor change was made to the form to acknowledge that there is now a flat, 1.39% tax on net excise income in place of the former 1%/2% tax. But other than that, the form is still clumsy and poorly arranged. 

  • Code Section 754: Allocating Gain Where it Belongs

    By:
    Dean L. Surkin, JD, LLM
    |
    May 1, 2023
    The genesis of Code Section 754 stretches back to the first third of the 20th century, as the IRS tried to combat tax avoidance through income shifting from higher-bracket taxpayers to lower-bracket taxpayers.

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

    By:
    Carl Fiore, JD, LLM
    |
    May 1, 2023
    As the calendar turns to 2023, 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.

  • Final Subpart F Regulations and Domestic Partnership Tax Reporting

    By:
    Sean Dokko, JD, LLM (taxation) and Suzy Lee, CPA 1
    |
    May 1, 2023
    On January 25, 2022, the Department of the Treasury and the Internal Revenue Service (collectively, “the Treasury”) published in the Federal Register final regulations (T.D. 9960) which generally treat a domestic partnership2 as an aggregate of its partners for purposes of determining whether, and to what extent, its partners have Subpart F inclusions (the final Subpart F Regulations).3 Application of the final Subpart F Regulations can affect a domestic partnership’s Schedules K-1, K-2 and K-3 reporting.
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Tax Jokes
  

What does an accountant say when getting on a train? Mind the GAAP.
 
https://parade.com/1317763/jessicasager/accounting-jokes/

One Big Beautiful Bill Act: Tax Deductions for Woking Americans and Seniors, Internal Revenue Service

IRS Staff Cuts Could Put Burden on Practitioners to Explain OBBBA, Association of International Certified Professional Accountants

Long's IRS Era: Implementing the 'Big Beautiful Bill' and Agency's Culture Shift, The Trusted Professional

Expert: OBBBA Does Not End Tax Credits Right Away, The Trusted Professional

Congress Passes Act Allowing Tax Relief When a State Declares Disaster, Association of International Certified Professional Accountants

National Taxpayer Advocate Issues Mid-Year Report to Congress, Internal Revenue Service

TIGTA: IRS Reduces Workforce by 25 Percent, Jeopardizing Upcoming Filing Season,The Trusted Professional

IRS Withdraws Proposed Regulation on Built-In Gains and Losses Under Section 382,The Trusted Professional

*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.