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The Supremes

The Constitution has figured prominently in the news of late. In the days preceding the initial discussions among members of the Administration and the Congressional leadership regarding the debt ceiling, several prominent Democrats stated that the President has the authority under the 14th Amendment to the Constitution[i] to unilaterally raise the debt ceiling. Last Sunday, the President himself told reporters he believes he has this authority, though “he acknowledged potential legal challenges could still lead the nation to default if he went that route.”[ii]

Continue Reading Supreme Court Upholds IRS Collections Summons Without Notice
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Hasta La Vista N.Y.

Wealthy individuals continue to leave New York[i] for tax friendlier jurisdictions.

Be Prepared[ii]

Some of these taxpayers take a very methodical approach toward planning for their departure. They consult their tax advisers many months, if not a few years, in advance of any move.[iii] They educate themselves in the rules that New York will apply to determine their tax residence. Then they formulate a plan and implement it in a very deliberate way.

Continue Reading Can You Be Sure You’ve Left New York Before The Sale of Your Business? Will It Matter?
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Solace in the Mundane?  

At war with Russia in eastern Europe, a nascent competing world order, mass shootings and bank failures at home, questionable audit practices by the Big 4 . . . everywhere, debt ceilings and the risk of default, inflation, tighter credit, recession, crypto-nonsense, recreational cannabis, legalized gambling, men competing in women’s sports, a nation divided over all too many things, the Knicks down to the Heat 3 games to 2,[i] the prospect of Biden vs Trump II,[ii]. . . , the list goes on.[iii]

Continue Reading Indirectly Held Profits Interests and Rev. Proc. 93-27
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Charitable Giving Update

According to a recent report on charitable giving, the number of donors at every level of giving dropped during the first three quarters of 2022.[i] The number of new donors was down by over 19 percent and the number of “newly retained” donors was down by almost 25 percent. The number of individual donors was down 7 percent.

That said, the amount donated was up 4.7 percent. According to the report, however, “the amount of goods and services that money could purchase was down,” citing the rate of inflation.

Continue Reading Selling Your Business? Careful of Pre-Sale Contributions of Stock to Charity
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A Dirty Business?

The art world is replete with tales of whodunits, forgeries, thefts, money laundering, looting of antiquities, murders, ancient curses, etc. You might say it’s a perfect environment for the more “sophisticated” type of criminal.[i] For the same reasons, it has proven to be a rich source of material for literature and Hollywood – “art” imitating life, as they say.

Continue Reading Sotheby’s N.Y. Sales Tax “Woes” Revisited
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Don’t Wait for Us

On March 20, 2023, Senators Warren, Sanders, Van Hollen, and Whitehouse addressed a letter to Treasury Secretary Yellen in which they urged Yellen “to use [her] existing authority to limit the ultra-wealthy’s abuse of trusts to avoid paying taxes.”[i]

Continue Reading The Federal Attack on Grantor Trusts: The Demise of Basis Step-Up at Death?
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Every year, the IRS compiles a list of common scams that taxpayers may encounter – its so-called “Dirty Dozen.”

Today, the Service wrapped up the annual Dirty Dozen list of tax scams for 2023 with a reminder for taxpayers, businesses and tax professionals to watch out for these schemes throughout the year, not just during tax season.

To help folks with identifying, and staying away from, these scams, the IRS has provided an overview recapping this year’s Dirty Dozen scams.[i]

Continue Reading IRS Wraps Up Its 2023 Dirty Dozen List
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Many years ago, New York revised its personal income tax law to achieve close conformity with the Federal system of income taxation. The stated purpose for the revision was to simplify tax return preparation, improve compliance and enforcement, and aid in the interpretation of tax law provisions.[i] In furtherance of this policy of conformity, as the Code is amended by Congress, New York automatically adopts the Federal changes.[ii]

Continue Reading New York Examines Federal Income Tax Issues –Conformity and . . . Disclosure?