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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?
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What Is It?

Where one stands on an issue of tax law may depend upon context and perspective, including the facts and circumstances one finds relevant, and whom one is counseling or representing.[i] 

Tax advisers often find themselves in situations in which they must ascertain either the “true” nature of a transfer of property between taxpayers[ii] – what they intended – or the character of the property that is the subject of the transfer. The determination of one may influence the outcome as to the other.

Continue Reading Sale of Partnership Interests . . . In the Ordinary Course of Business?
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Annual Ritual

The Budget and Accounting Act of 1921 established the requirement that the President submit a budget to Congress for the upcoming fiscal year.[i] Among other things, the proposed federal budget affords the President an opportunity to identify priorities for the next fiscal year, to quantify how much the Administration expects it will cost the government to attain the President’s goals, and to explain how and from what sources the funds needed to cover these expenses will be raised.

Continue Reading The President’s 2024 Federal Budget: “Reforming” the Taxation of High-Income Taxpayers
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Have you ever wondered whether you were barking up the wrong tree? That the solution to a problem may be found, not in the approach to which you were already committed and invested, but in an altogether different direction?

Query whether Congress, if it ever experienced such an epiphany or moment of realization, would be capable of changing course and adopting what may prove to be a more fruitful, though politically more challenging, solution.  

Continue Reading The Closely Held Business and The Tax Gap
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History is replete with examples of leaders who chose to battle, or who were forced into defending against, enemies on two fronts. Rarely did it end well for the combatant that occupied the middle ground.

In a sense, New York has stumbled into a similar situation with two of its neighbors, New Jersey to the west and Connecticut to the east.[i] The three states,[ii] which comprise the Tri-State Area centered on New York City, are openly competing with one another for badly needed tax dollars.

Continue Reading New York’s Convenience of the Employer Rule – New Jersey and Connecticut Respond
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“Don’t Come Around Here”[i]

There have been some interesting developments of late with respect to the ownership of real property in parts of the English-speaking world. For example, Canada has imposed a temporary ban on the purchase of such property by foreigners. In Australia, a foreigner has to be granted permission by a federal governmental body before they can purchase real estate. Florida is considering a ban on foreign ownership of residential and farm properties.

The principal rationale given by these jurisdictions for limiting foreign ownership of residential property within their boundaries: wealthy foreigners have been parking their cash in such properties and, in the process, have priced too many local residents out of the market.

Continue Reading Foreign Individuals Holding U.S. Real Property, or Left Holding the Bag?