The IRS has determined that any person required to pay Federal gift tax or generation-skipping transfer tax or to file IRS Form 709 (United States Gift and Generation-Skipping Transfer Tax Return) on April 15, 2020, is deemed to be affected by the COVID-19 emergency and, so, should be granted an extension of time within which
Farrell Fritz P.C.
Think Before You Gift, But Don’t Take too Long
By Farrell Fritz P.C. on
Posted in Federal
Optimal Timing?
During the last twenty years, there have been a number of times during which the owners of closely held business entities have been encouraged – “urged” might be a better word, at least in some cases – by many advisers to take advantage of what may be described as “adverse” economic circumstances to…
Coronavirus & Business Losses: Suspend or Repeal – The TCJA Loss Limitation Rules
By Farrell Fritz P.C. on
Posted in Federal
The Lockdown
We are in a Coronavirus-induced lockdown. Most places of business are either closed or are open on a very limited basis. Social distancing is the order of the day. Those who can work remotely are doing so.[i] Many don’t have that option.
Certain businesses are experiencing an uptick in revenue as a…
Recapitalizing Debt To Defer Payment of the Estate Tax – Good Idea?
By Farrell Fritz P.C. on
Posted in Federal
Estate Planning 101
A basic precept of effective estate planning is for a member of an older generation to transfer[i] property to a family member of a younger generation – for example, stock in a closely held corporation – that is reasonably anticipated to appreciate in value over time. In this way, not only…
One Corporation, One Property, Two Shareholders – Can They Be Separated? Without Tax?
By Farrell Fritz P.C. on
Posted in Federal
A Basic Principle
Do you remember the scene from “History of the World Part I” when Mel Brooks, in the role of Moses, calls out “Hear me, oh hear me! All pay heed! The Lord, the Lord Jehovah has given unto you these fifteen [he drops one of the three tablets cradled in his arms…
Reliance on the Tax Adviser – There Are Limits
By Farrell Fritz P.C. on
Posted in Federal
We’re well into the income tax return “preparation-n-filing” season. It’s the time of year during which many businesses and their owners recognize the importance of working with a competent tax professional, one on whom they may rely not only for their tax reporting services but, more importantly, for the practical tax guidance they provide throughout…
Sometimes, You Want To Be “At Risk” – Even In Healthcare
By Farrell Fritz P.C. on
Posted in Federal
Keeping It Real
Contrary to what has long been an all-too-popular belief,[i] there is a method to the Code. That is not to say that no part of it is arbitrary, or that none of its provisions are tainted by political dealings, or that it cannot be improved. After all, it is the product…
Where New York State and City Transfer Taxes Meet: Does A Lease Make Sense?
By Farrell Fritz P.C. on
Posted in State Tax Issues
When It Rains
Sometimes you go for weeks without having to consider a particular tax issue in any depth. Then, unexpectedly, that issue comes to the forefront of several projects. That was my experience this past week when it seemed as though almost every other person who came to my office had a question concerning…
Sale of Stock + Target’s Capitalized Costs = Creation of Intangible? Nope
By Farrell Fritz P.C. on
Posted in Federal
Sale of Stock
Ask a business owner to identify the parties to an agreement for the purchase and sale of the stock of a target corporation, perhaps even their own. After giving you a quizzical look,[i] they will likely reply that, on the one hand, you have the target’s shareholders, who will be selling…
States’ Rights, State Taxation, And . . . New York “S” Elections?
By Farrell Fritz P.C. on
Posted in State Tax Issues
How Did We Get Here?
On September 9, 1776, Congress officially adopted “United States” of America as the name of our then-newly-born nation. The former British colonies had previously referred to themselves as the “United Colonies.” In March of 1781, the Articles of Confederation went into effect, after having been ratified by all thirteen States.…