Manoj Viswanathan, UC-Hastings, has made available for download his article, The Qualified Small Business Stock Exclusion: How Startup Shareholders Get $10 Million (Or More) Tax-Free, 119 Colum. L. Rev. F. ___ (2019). The Abstract is as follows: The IPO parade of 2019 is making the early shareholders of technology startups such as Uber, Lyft, Slack, … Continue reading Viswanathan: The Qualified Small Business Stock Exclusion — How Startup Shareholders Get $10 Million (Or More) Tax-Free, Virginia Tax Review (2020).
The Tax Court, in Rosenberg v. Commissioner, T.C. Memo 2019-124, held that an IRA distribution, made after a couple divorced, was taxable and subject to the 10% additional tax because there was no exception to the 10% additional tax applicable and because there was no equitable exception to the distribution being taxable. To see full opinion, click, … Continue reading Rosenberg v. Commissioner: IRA distribution, made after a couple divorced, taxable & subject to the 10% additional tax
According to KPMG, the role of U.S.-based cross-border business traveler is growing with today’s increasingly mobile business environment. Consequently, the ability of multistate employers and their third-party providers to proactively manage the overall compliance issues associated with domestic, state-to-state, and short-term travel is vital to bringing together both business and regulatory demands. Add to the … Continue reading KPMG Report: Nonresident state income tax withholding, cross-border business travelers (Oct. 1, 2019)
The IRS issued a draft of the tax year 2019 Form 1065, U.S. Return of Partnership Income (PDF), and its Schedule K-1, Partner’s Share of Income, Deductions, Credits, etc (PDF). The changes to the form and schedule aim to improve the quality of the information reported by partnerships both to the IRS and the partners of such entities. For … Continue reading IRS releases draft 2019 Forms 1065, 1120-S, and Schedules K-1 (September 30, 2019)
By Mark Klein & Dan Kelly If you have ever moved, you know it’s not easy! The same can be said about changing your domicile. Tax Departments are aggressive and thorough in their pursuit of taxpayers who claim to move, and taxpayers who are not focused on the most important actions, primary factors, and who do not … Continue reading Successfully Moving to a Zero or Low Tax State
Charles J. Reichert, has published his article, Taxpayer allowed a deduction under claim of right in Mihelick v Commissioner (11th Circuit June 18, 2019), in the Journal of Accountancy (Sept. 1, 2019). His articles discusses an eleventh circuit case where a divorced spouse was allowed to deduct her indirect repayment of an amount previously included … Continue reading Reichert, Taxpayer allowed a deduction under claim of right, J. Accountancy (Sept. 1, 2019)
From taxation complexity to cyberthreats, what are today’s top concerns? By Randy Abeles, Tax Partner, RSM US LLP Family offices come in all shapes and sizes and the differences from one to another can be vast. And, yet family offices have common challenges—and opportunities—especially in today’s dynamic business environment. From addressing the complexities of taxation … Continue reading Emerging Issues for the Family Office