Forbes: Federal Prosecutors Coming Down Hard On Abusive Conservation Easement Promoters (March 5, 2022)

Forbes has published an article, “Federal Prosecutors Coming Down Hard On Abusive Conservation Easement Promoters”, which discusses punishments for those that utilize Syndicated Conservation Easement (SCE) products. The article begins as follows:  Syndicated Conservation Easement (SCE) products aren’t produced in vacuums. There are teams of people constructing and assembling a variety of documents that support … Continue reading Forbes: Federal Prosecutors Coming Down Hard On Abusive Conservation Easement Promoters (March 5, 2022)

High-Risk, High-Reward: A Case For Tax Deferral | NYU Law Review

Scott Greenberg has published an article, High-Risk, High-Reward: A Case For Tax Deferral, in the NYU Law Review. The summary is as follows: The federal tax code contains a number of provisions that reduce taxes on personal and business investment income. Many of these provisions fall into two categories: yield exemption provisions, which reduce taxes … Continue reading High-Risk, High-Reward: A Case For Tax Deferral | NYU Law Review

IRS Updates Practice Unit on Section 245A Dividends Received Deduction Overview (September 13, 2021)

The IRS has updated its practice unit on Partner’s Outside Basis. The overview is as follows: The Tax Cuts and Jobs Act (TCJA) transitioned the United States from a primarily deferral-based international tax system to a participation exemption system coupled with immediate taxation of certain offshore earnings. This transition was implemented through several interlocking provisions … Continue reading IRS Updates Practice Unit on Section 245A Dividends Received Deduction Overview (September 13, 2021)

NY Times: A Lavish Tax Dodge for the Ultrawealthy Is Easily Multiplied (December 28, 2021)

Jesse Drucker and Maureen Farrell, in their New York Times article, discusses the tax breaks, originally aimed at small businesses, that are utilized by the ultrawealthy. Their article, “A Lavish Tax Dodge for the Ultrawealthy Is Easily Multiplied”, begins as follows: This is the story of the incredible cloning tax break.In 2004, David Baszucki, fresh off a stint … Continue reading NY Times: A Lavish Tax Dodge for the Ultrawealthy Is Easily Multiplied (December 28, 2021)

Procedurally Taxing: When Is a Late Return Not Really “Late”?? – Part 1 (December 3, 2021)

Bob Probasco, Senior Lecturer and Director Tax Dispute Resolution Clinic, has made available for download his article, “When Is a Late Return Not Really “Late”?? – Part 1” published on the Procedurally Taxing blog. The article begins as follows: The IRS released a legal memo recently on an issue I had never thought of before.  Would a … Continue reading Procedurally Taxing: When Is a Late Return Not Really “Late”?? – Part 1 (December 3, 2021)

Procedurally Taxing: When Is a Late Return Not Really “Late”?? – Part 2 (December 6, 2021)

Bob Probasco, Senior Lecturer and Director Tax Dispute Resolution Clinic, has made available for download his article, “When Is a Late Return Not Really “Late”?? – Part 2” published on the Procedurally Taxing blog. The article begins as follows: And now some observations and questions about that recent IRS legal memo on an overpayment interest issue.  The … Continue reading Procedurally Taxing: When Is a Late Return Not Really “Late”?? – Part 2 (December 6, 2021)

BDO USA: 2021 Year-end Tax Planning for Businesses (November 2021)

BDO USA has published an article, “2021 Year-end Tax Planning for Businesses”, published on BDO USA. The abstract is as follows: As the U.S. entered 2021, many assumed that newly elected President Joe Biden along with Democratic majorities in the House and Senate would swiftly enact tax increases on both corporations and individuals to pay … Continue reading BDO USA: 2021 Year-end Tax Planning for Businesses (November 2021)

David Hasen : Interest Deductibility Under the Income Tax (October 2021)

David Hasen, of UF Levin College of Law, has made available for download his article, "Interest Deductibility Under the Income Tax." The abstract is as follows: The tax treatment of interest expense is something of a muddle. In the earliestyears of the income tax, interest expense generally was deductible, though borrowingwas relatively uncommon and most … Continue reading David Hasen : Interest Deductibility Under the Income Tax (October 2021)

Herbert N. Beller: S Corporations as Shareholders, LLC Members, and Partners (October 18, 2021)

Herbert N. Beller, of Northwestern University - Pritzker School of Law; Sutherland Asbill & Brennan LLP, has made available for download his article, “S Corporations as Shareholders, LLC Members, and Partners” published in 172 Tax Notes Federal 1713 (2021) and 172 Tax Notes Federal 1915 (2021). The abstract is as follows: This two-part article focuses … Continue reading Herbert N. Beller: S Corporations as Shareholders, LLC Members, and Partners (October 18, 2021)

Breaking Down the Plan to Report Your Bank Account to the IRS (October 14, 2021)

According to Bloomberg News, I carried a certain amount of starry-eyed innocence with me early in my tax career. And I remember the day it started to fade. I had been anticipating finalizing a settlement for a client’s outstanding tax liability. On paper, I was convinced we would get what we wanted. Then I got … Continue reading Breaking Down the Plan to Report Your Bank Account to the IRS (October 14, 2021)

Forbes: S Corp To Partnership Conversion Under Build Back Better (October 1, 2021)

Forbes has published an article, “S Corp To Partnership Conversion Under Build Back Better”, which discusses provisions of the Build Back Better Act such as the differing restrictions between S Corporations and Partnerships. The article begins as follows:  One of the most exciting provisions of the Build Back Better Act, to me anyway, is the … Continue reading Forbes: S Corp To Partnership Conversion Under Build Back Better (October 1, 2021)

Corporate State Tax Updates – June 2021

By Georgia Lo The following are recent significant State Corporate Tax developments for the month of June that may be of interest to estate and business planners, organized by state. California: On June 3, AB-71, regarding Global Intangible Low-Taxed Income and repatriation income, was moved to the inactive file. Colorado: On June 23, H.B.21-1311 was … Continue reading Corporate State Tax Updates – June 2021

IRS Updates Practice Unit on Foreign-Derived Intangible Income (June 28, 2021)

The IRS has updated its practice unit on Foreign-Derived Intangible Income (FDII). The overview is as follows: The Tax Cuts and Jobs Act enacted section 250, which provides for a deduction with respect to Global Intangible Low-Taxed Income (GILTI) and Foreign-Derived Intangible Income (FDII). The deduction is only available to domestic corporations (except that the … Continue reading IRS Updates Practice Unit on Foreign-Derived Intangible Income (June 28, 2021)

BDO: South Carolina Enacts PTE Tax Election As Workaround To $10K Salt Cap (June 2021)

Angela Acosta of BDO has published an article, “South Carolina Enacts PTE Tax Election As Workaround To $10K Salt Cap,” which discusses the logistics of South Carolina following in the footsteps of other states and implementing PTE taxation options. The article begins as follows: South Carolina enacted S.B. 627 on May 17, 2021, joining 11 other states … Continue reading BDO: South Carolina Enacts PTE Tax Election As Workaround To $10K Salt Cap (June 2021)

KPMG Podcast: Greener on the Other Side? The Inbound Perspective of the Green Book (June 15, 2021).

KPMG’s podcast discusses the possible implications of the Biden administration tax framework regarding multinational corporations with U.S. operations. The abstract is as follows: After much anxious anticipation, the Biden administration finally showed its cards. The Treasury Department’s General Explanations of the Administration’s Fiscal Year 2022 Revenue Proposals (the “Green Book”) provided a bit more detail … Continue reading KPMG Podcast: Greener on the Other Side? The Inbound Perspective of the Green Book (June 15, 2021).

IRS Updates Practice Unit on Partner’s Outside Basis (May 19, 2021)

The IRS has updated its practice unit on Partner’s Outside Basis. The overview is as follows: Background A partnership is a relationship between two or more persons who join together to carry on a trade, business, or investment activity. Each partner has a basis in his partnership interest. The partner’s basis in his partnership interest … Continue reading IRS Updates Practice Unit on Partner’s Outside Basis (May 19, 2021)

Susan C. Morse: The Quasi-Global GILTI Tax (June 8, 2021)

Susan C. Morse, of the University of Texas at Austin - School of Law, has made available for download her article, "The Quasi-Global GILTI Tax", published in the Pittsburgh Tax Review, volume 18. The abstract is as follows: The U.S. minimum tax on global intangible low-taxed income, or GILTI, suggests a broad way of thinking … Continue reading Susan C. Morse: The Quasi-Global GILTI Tax (June 8, 2021)

Forbes: Democrats Reintroduce ‘Millionaires Surtax’ Bill (June 10, 2021)

Forbes has published an article, "Democrats Reintroduce 'Millionaires Surtax' Bill," which provides key facts and a brief summary of the new surtax bill. The article begins as follows: Days after a bombshell ProPublica report revealed many of the wealthiest Americans have paid very little in federal income tax, a group of Democrats reintroduced legislation Thursday to institute a surtax … Continue reading Forbes: Democrats Reintroduce ‘Millionaires Surtax’ Bill (June 10, 2021)

Bloomberg Wealth: World’s Richest Face Tax Blow After 40% Wealth Surge to $8.4 Trillion (June 10, 2021)

Ben Steverman, Laura Davison, and William Horobin of Bloomberg Wealth, have recently made available their article that discusses politicians' expected endorsement of tax plans that will plug legal loopholes used by the wealthiest individuals and corporations to pay lower tax rates. Their article, "World’s Richest Face Tax Blow After 40% Wealth Surge to $8.4 Trillion," … Continue reading Bloomberg Wealth: World’s Richest Face Tax Blow After 40% Wealth Surge to $8.4 Trillion (June 10, 2021)

BDO: IRS Streamlines Automatic Consent Procedures For CFC Depreciation Method Changes, Clarifies Treatment Of Catch-Up Adjustment (June 2021)

BDO has published an article, “IRS Streamlines Automatic Consent Procedures For CFC Depreciation Method Changes, Clarifies Treatment Of Catch-Up Adjustment,” which discusses new filing procedures released by the IRS for certain foreign corporations (CFCs). The article begins as follows: On May 11, 2021, the IRS and Treasury released Rev. Proc. 2021-26, which provides streamlined filing procedures … Continue reading BDO: IRS Streamlines Automatic Consent Procedures For CFC Depreciation Method Changes, Clarifies Treatment Of Catch-Up Adjustment (June 2021)