Forbes: A Tax Update On The Infrastructure and Budget Bills (October 7, 2021)

Forbes has published an article, “Crunch Time: A Tax Update On The Infrastructure and Budget Bills”, which discusses the current state of several bills currently held up in Congressional proceedings The article begins as follows:  When we last checked in on Congress in August, at the top of the House's to-do list were two record-breaking bills: … Continue reading Forbes: A Tax Update On The Infrastructure and Budget Bills (October 7, 2021)

TaxProfBlog – South Dakota’s Tax Avoidance Schemes Represent Federalism At Its Worst (October 8, 2021)

Paul Caron has published an article on the TaxProfBlog, titled "South Dakota's Tax Avoidance Schemes Represent Federalism At Its Worst", which discusses the release of the Pandora Papers and ways both Congress and states themselves can react in order to mitigate the negative effects discussed in the papers from being repeated in the future. The … Continue reading TaxProfBlog – South Dakota’s Tax Avoidance Schemes Represent Federalism At Its Worst (October 8, 2021)

NY Times + Northern Trusts Institute: Join Us for a Conversation on the Business of Longevity (Oct. 12, 2021)

The New York Times and the Northern Trust Institute have partnered to present Conversation on the Business of Longevity on Oct. 12, 2021. The summary is as follows: Why has the idea of immortality (or at least living much longer) inspired billions in investment? Harvard researcher and biotech founder David Sinclair joins Andrew Ross Sorkin … Continue reading NY Times + Northern Trusts Institute: Join Us for a Conversation on the Business of Longevity (Oct. 12, 2021)

TaxProf Blog – Supreme Court To Decide Whether 30-Day Time Limit For Tax Court Appeal Of IRS Determination Is A Jurisdictional Requirement (October 21, 2021)

Paul Caron has published an article on the TaxProf Blog, titled “Supreme Court To Decide Whether 30-Day Time Limit For Tax Court Appeal Of IRS Determination Is A Jurisdictional Requirement,” which discusses the Supreme Court's recent decision to grant a certiorari to resolve a circuit split. The article begins as follows: The Supreme Court yesterday … Continue reading TaxProf Blog – Supreme Court To Decide Whether 30-Day Time Limit For Tax Court Appeal Of IRS Determination Is A Jurisdictional Requirement (October 21, 2021)

Forbes: More Offshore Account Prosecutions For Secret Accounts Seeking Heavy Prison Time (September 29, 2021)

Forbes has published an article, “More Offshore Account Prosecutions For Secret Accounts Seeking Heavy Prison Time”, which discusses the harsh penalties the IRS and U.S. Justice Department continue to give out to individuals who intentionally evade taxation through offshore accounts. The article begins as follows: These days, the IRS and Justice Department seem more intent … Continue reading Forbes: More Offshore Account Prosecutions For Secret Accounts Seeking Heavy Prison Time (September 29, 2021)

Daniel J. Hemel and Robert Lord: Closing Gaps in the Estate and Gift Tax Base (August 13, 2021)

Daniel J. Hemel of University of Chicago - Law School and Robert Lord of Americans for Tax Fairness have made available for download their article, "Closing Gaps in the Estate and Gift Tax Base," published in SSRN. The abstract is as follows: Three transfer tax minimization mechanisms—zeroed-out grantor retained annuity trusts (GRATs), intentionally defective grantor … Continue reading Daniel J. Hemel and Robert Lord: Closing Gaps in the Estate and Gift Tax Base (August 13, 2021)

Marilyne Sadowsky: The History of International Tax Law (March 16, 2021)

Marilyne Sadowsky, of Sorbonne Law School, has made available for download her article, The History of International Tax Law, published in the OUP Handbook of International Tax Law. The abstract is as follows: The article argues that international tax law is not a recent law born in the 1920s, it has always existed.From “Miksum” to … Continue reading Marilyne Sadowsky: The History of International Tax Law (March 16, 2021)

NY Times (July 8, 2021): Baby Boomers: Rich With Real Estate and Not Letting Go

Michael Kolomatsky, in his New York Times article, discusses the bulk of real estate wealth held by baby boomers and its impacts on the housing market, combined with the COVID-19 pandemic. His article, "Baby Boomers: Rich With Real Estate and Not Letting Go", begins as follows: The concept of aging in place, already growing in popularity … Continue reading NY Times (July 8, 2021): Baby Boomers: Rich With Real Estate and Not Letting Go

Edward T. Killen: Further Extended Modification of Exam Activity (June 28, 2021)

Edward T. Killen, the Deputy Commissioner of Tax Exempt & Government Entities Division, has released memorandum that supersedes the previous memorandum issued on December 15, 2020, entitled, “Extended Modification of IDR Enforcement Timelines due to COVID-19 Considerations and Resumption of Exam Activity”. It extends the guidance regarding resumption of TE/GE exam activities post July 15, … Continue reading Edward T. Killen: Further Extended Modification of Exam Activity (June 28, 2021)

Abigail Disney: I Was Taught From a Young Age to Protect My Dynastic Wealth (June 17, 2021)

Abigail Disney has made available for download her article, "I Was Taught From a Young Age to Protect My Dynastic Wealth," published in The Atlantic. The article begins as follows: When ProPublica published its report last week on the tax profiles of 25 of the richest Americans, jaws dropped across the United States. How was it possible … Continue reading Abigail Disney: I Was Taught From a Young Age to Protect My Dynastic Wealth (June 17, 2021)

Procedurally Taxing: Nuance in Determining the Taxpayers Last Known Address – Designated Orders, November 2, 2020 (June 17, 2021)

Caleb Smith, Visiting Associate Clinical Professor and the Director of the Ronald M. Mankoff Tax Clinic at the University of Minnesota Law School, discusses the recent Ninth Circuit opinion that applies the Declaratory Judgment Act and the path that led to the court’s finding that the DJA prevented the court from reaching the merits of … Continue reading Procedurally Taxing: Nuance in Determining the Taxpayers Last Known Address – Designated Orders, November 2, 2020 (June 17, 2021)

Corporate State Tax Updates – May 2021

Georgia Lo The following are recent significant State Corporate Tax developments for the month of May that may be of interest to estate and business planners, organized by state.  Alabama: On May 14, H.B. 588 was signed into law, providing credits to owners, members, partners, or shareholders of an electing pass-through entity in an amount … Continue reading Corporate State Tax Updates – May 2021

NY Times: Rich Americans Like Bezos, Musk, Buffett Paid Little or No Federal Income Taxes (June 8, 2021)

The New York Times is reporting that an analysis by ProPublica based on Internal Revenue Service documents showed billionaires like Jeff Bezos and Elon Musk benefited from vagaries in the tax code, often paying little to no federal income taxes.. That NY Times articles comes at a time when the Biden Administration is proposing significant … Continue reading NY Times: Rich Americans Like Bezos, Musk, Buffett Paid Little or No Federal Income Taxes (June 8, 2021)

Leopoldo Parada: Tax Treaty Entitlement and Fiscally Transparent Entities: Improvements or Unnecessary Complications? (January 21, 2021)

Leopoldo Parada, of University of Leeds School of Law, has made available for download his article, Tax Treaty Entitlement and Fiscally Transparent Entities: Improvements or Unnecessary Complications?, published in J. Wheeler (ed), The Aftermath of BEPS (IBFD, 2020). The abstract is as followed: This chapter analyses the recent modifications to the 2017 OECD Model Tax … Continue reading Leopoldo Parada: Tax Treaty Entitlement and Fiscally Transparent Entities: Improvements or Unnecessary Complications? (January 21, 2021)

Forbes: Tax Rules Your Lawyer Might Not Know (April 19, 2021)

Forbes has published an article, "Tax Rules Your Lawyer Might Not Know," which discusses tax rules for settlement agreement . The article begins as follows: Many lawyers are asked about tax issues, at least in a general way. For example, clients may ask whether legal fees they pay are tax deductible. Unfortunately, many tax issues … Continue reading Forbes: Tax Rules Your Lawyer Might Not Know (April 19, 2021)

Ways & Means Approves SECURE 2.0 Bill

The House Ways & Means Committee approved, on a bipartisan basis,  H.R. 2954, the “Securing a Strong Retirement Act of 2021,” sometimes referred to as SECURE 2.0 SECURE 2.0 seeks to expand retirement plan coverage and increase retirement savings, through a variety of provisions. expanding automatic enrollment, increasing the age mandatory distributions are required to … Continue reading Ways & Means Approves SECURE 2.0 Bill

Corporate State Tax Updates – March 2021

By Georgia Lo The following are recent significant State Corporate Tax developments for the month of March 2021 that may be of interest to estate and business planners, organized by state.  Alabama: The Alabama Court of Appeals recently upheld the state’s mandatory corporate income tax return requirement for passthrough entities with non-resident members. Under state law, … Continue reading Corporate State Tax Updates – March 2021

Paul Graham Op Ed: How People Get Rich Now (April 2020)

Paul Graham, founder of Y Combinator, wrote an op ed on his extensive blog, How People Get Rich Now. The article begins as follows: Every year since 1982, Forbes magazine has published a list of the richest Americans. If we compare the 100 richest people in 1982 to the 100 richest in 2020, we notice some big … Continue reading Paul Graham Op Ed: How People Get Rich Now (April 2020)

IRS Practice Unit Updated: Receipt of Dividends or Interest from a Related CFC (March 29, 2021)

The IRS has updated its practice unit on receipt of dividends or interest from a related controlled foreign corporation. The overview is as follows: Note: This Unit was revised to include the extension of the IRC 954(c)(6) look through rule for CFCs with tax years beginning before January 1, 2026. This extension was part of … Continue reading IRS Practice Unit Updated: Receipt of Dividends or Interest from a Related CFC (March 29, 2021)