Legal Updates & Commentary for Tax & Estate Planning
Ask anyone outside the United States what comes to mind when they think about an American New Year’s celebration, and the odds are pretty good they will mention the ball drop in New York City’s Times Square.
That’s all well and good, but let me ask you, does the Empire State have…
On March 1, 2020, New York had its first confirmed case of the coronavirus.[i] On March 6, pursuant to the Coronavirus Preparedness and Response Supplemental Appropriations Act[ii], over $8.3 billion in emergency Federal funding was appropriated to combat the spread of the coronavirus. On March 7, Governor Cuomo declared…
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…
It’s late August – again. As usual, many business owners are looking forward to having all of their employees back at work and ready to make the final push for a successful year.[i] Others, nearing retirement, and who may be contemplating the arrival of another winter, are considering whether it…
Over the last several weeks, we have explored various aspects of the choice of entity dilemma that confronts the owners of many closely held businesses, and we have considered how the Tax Cuts and Jobs Act[i] may influence their decision.
In the process, you may have realized that one form of…
As we enter the “season of giving” and the end of yet another year, the thoughts of many tax advisers turn to . . . tax planning.(i) In keeping with the spirit of the season, an adviser may suggest that a client with a closely held…
Dr. Wallace Wrightwood: “You’ve seen hundreds, thousands of pigeons, right?”
George Henderson: “Of course.”
Dr. Wallace Wrightwood: “Have you ever seen a baby pigeon? Well neither have I. I got a hunch they exist.”[i]
When was the last time you pored over a judge’s analysis of the bona fides of a family limited partnership (“FLP”),…
When the Tax Cuts and Jobs Act[1] was introduced on November 2, 2017, perhaps the single most important issue on the minds of many closely held business owners was the future of the estate tax: was it going to be repealed as had been promised? A closely related question – and perhaps of equal…
Last week, we reviewed the various U.S. federal income tax consequences that may be visited upon a foreign person who owns and operates U.S. real property (“USRP”). Today we will consider the U.S. federal gift and estate tax consequences of which a foreign individual must be aware when investing in USRP.
As you…
They were years in the making – proposed regulations that seek to address what the IRS believes are abuses in the valuation of family-owned business and investment entities. Based upon the volume of commentary generated in response to the proposed rules, it is clear that the IRS has struck the proverbial raw…
