Uptick in Business Divorces?

I’ve read a number of articles over the last few weeks in which marriage counselors have been predicting a wave of divorce filings once the COVID-19 quarantine has been lifted.[i]

That may be – we’ll just have to wait and see.[ii] Query, however, whether “business divorces” will follow suit?

The quarantine and the resulting … Continue Reading

The Tax Gene?

King of Swamp Castle: One day, lad, all this will be yours.

Prince Herbert: What, the curtains?

King: No, not the curtains, lad. I’m talking about all of my business and investment interests, along with the related tax reporting positions.[I]

Have you ever wondered how much our parental genes define us? What about … Continue Reading

If there was one part of the Tax Cuts and Jobs Act (“TCJA”) that estate planners were especially pleased to see, it was the increase in the basic exclusion amount from $5.49 million, in 2017, to $11.18 million for gifts made, and decedents dying, in 2018.[i] However, many estate planners failed to appreciate the potential impact of an income … Continue Reading

Earlier this month, the IRS proposed regulations regarding the additional first-year depreciation deduction that was added to the Code by the Tax Cuts and Jobs Act (“TCJA”).[i] The proposed rules provide guidance that should be welcomed by those taxpayers that are considering the purchase of a closely held business or, perhaps, of an interest in such a business, and … Continue Reading

Our last post reviewed the “20% deduction” that may now be available to the owners of certain pass-through entities based upon their qualified business income; as we saw, there are many questions that remain unanswered.[1]

Today’s post is the first of two[2] this week in which we continue our consideration of those income tax provisions of the Tax Cuts and … Continue Reading

Coming to America

Whether they are acquiring an interest in U.S. real property or in a U.S. operating company, foreigners seek to structure their U.S. investments in a tax-efficient manner, so as to reduce their U.S. income tax liability with respect to both the current profits generated by the investment and the gain realized on the disposition of the investment, … Continue Reading

Oops

The last few posts have focused upon the “tax-free” contribution of property to a partnership. Today, we’re “doing a 180,” as they say (whoever “they” are), and considering how the acquisition of assets may be structured so as to provide the buyer with a cost, or “stepped-up,” basis in those assets. It sounds simple enough, but there will be … Continue Reading