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The Long-Term View

Among its core functions, federal tax policy seeks to encourage those behaviors among businesses that, in the long run, will have a lasting positive effect upon the nation’s economy as a whole.[i]

Implicit in this approach toward tax legislation is the enactment of a set of relatively constant and long-lasting rules on which businesses[ii] may rely when planning for the future.

Under this long-term view of tax policy, a provision that is drafted to be short-lived probably should not be adopted unless Congress reasonably determines the provision will generate benefits that endure well beyond its expiration.  Continue Reading Nothing Lasts Forever –Expiring Tax Provisions

Our Holiday

Thanksgiving has been a national holiday in the U.S. since 1870. During most of that period, at least until recently, it has also been a unifying force as immigrants to this country, eager to be assimilated to American society,[i] and recognizing the holiday’s universal message of gratitude,[ii] have adopted the day as their own.[iii]

In 1863, only months after the Battle of Gettysburg and the Siege of Vicksburg, and a few years before Thanksgiving officially became a national holiday, President Lincoln issued the following Proclamation:[iv]Continue Reading This Thanksgiving, Give Thanks for Taxes . . . or Not

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

Taxing the Rich

During the last couple of months, as we headed into what most folks – excluding transactional attorneys – call the “Holiday Season,”[i] tax authorities from around the globe have been calling for increased taxes on the rich, however one chooses to define this class of individuals.

The chief economist for the European Central Bank, relying on macroeconomic policy and concepts of “fairness,” advised governments to tax the rich to support society’s vulnerable groups.[ii]

In the U.K., His Majesty’s Revenue & Customs announced an initiative to pursue tax fraud by the wealthy and mid-size businesses. In fact, it has been reported that HMRC plans to go so far as to assign agents to personally monitor the tax affairs of certain individuals – an odd variation on the “buddy system.”
Continue Reading Pigs Get Fed, and Pay Their Taxes, But Hogs – That Remains to be Seen

I am delighted to launch TaxSlaw – where those hungry for tax knowledge come to chow down. Those who have been following me know that I have written about tax concerns for the closely-held business for more than a decade. I hope TaxSlaw– my opus, so to speak – will take that approach to…