Legal Updates & Commentary for Tax & Estate Planning
You may recall how clear it became, as the bill that would become the Tax Cuts and Jobs Act (“TCJA”)[i] moved through Congress in late 2017, that C corporations were about to realize a number of tax benefits, the most significant being the introduction of a flat federal corporate income tax rate…
How many times have you sat with a client who wants to leave N.Y. for a jurisdiction with a more pleasant “tax climate?” A place where the combined state and local personal income tax rate does not approach 12.87-percent,[i] where the sales tax is well below…
Tax and bankruptcy: “Can two divorced men share an apartment without driving each other crazy”[i] or “Two great tastes that taste great together”?[ii]
For years I have told my partners that there are two kinds of “codes”: those with an upper case “C”, like the Ten Commandments and the Internal Revenue…
Ask most New Yorkers what New York City has in abundance and you’ll get responses that are as varied as the personalities to whom the question is put. Museums, restaurants, performing arts, college students,[i] office buildings, street food, subway lines, cabs, dog walkers, rats, and politicians are sure to make…
One of the thorniest tasks to confront a tax adviser may be having to determine whether the business or investment relationship between two taxpayers constitutes a partnership for tax purposes.
Where the persons involved have formed a limited liability company or a limited partnership under state law, they have formed a tax law partnership[i]…
The reduction in the Federal income tax rate for C corporations, from a maximum of 35-percent to a flat 21-percent, along with several other changes made by the Tax Cuts and Jobs Act (the “Act”) that generally reflect a pro-C corporation bias, have caused the owners of many pass-through entities (“PTEs”) to…
In the weeks preceding the introduction of the bill that was just enacted as the Tax Cuts and Jobs Act (the “Act”), my colleagues teased me, “Lou, what are you going to do when Congress simplifies the Code?”
“Simplify?” I responded as I reached for the Merriam-Webster’s Dictionary that I have used since 1980 –…
What is It?
It is a frequently recurring issue for those who advise the owners of rental real property, but one that is rarely raised by the owners themselves: does the ownership arrangement constitute a partnership for income tax purposes?
The question appears to be fairly straightforward – just ask any client. “We haven’t executed…
